New York Court of Appeals

The People of the State of New York v. Matthew Ianniello

February 21, 196821 N.Y.2d 418

Summary

The Court reversed the dismissal of the criminal contempt indictment against Matthew Ianniello, holding that a Grand Jury witness who is a target of an investigation may be prosecuted for contempt for evasive testimony and that the denial of a brief consultation with counsel did not violate his right to counsel. The decision rests on the People v. Tomasello rule and an analysis of the limited scope of a witness's counsel rights in Grand Jury proceedings.