New York Court of Appeals

The People of the State of New York v. Steven Joseph Garofolo

April 3, 197946 N.Y.2d 592

Summary

The Court held that the defendant's written confession must be suppressed because counsel was not notified in a timely manner, that the earlier oral confession was admissible, that statements obtained while the defendant was in jail after his right to counsel attached were inadmissible, and that these errors were not harmless, requiring a new trial. The majority emphasized the need for prompt police procedures to notify counsel. Judge Jasen dissented, arguing that the written confession error could be harmless and that the conviction should be affirmed.