New York Court of Appeals
The People of the State of New York v. Jeffrey Young
April 7, 199279 N.Y.2d 365
Summary
The Court held that the Appellate Division erred in applying a "commonsense" exception to the Rosario disclosure rule and affirmed the conviction while remanding for determination of whether the undisclosed report contained statements of a testifying officer. The Court reaffirmed the per‑se reversal rule for Rosario violations and ordered the case sent back to the trial court for further proceedings.