New York Court of Appeals
The People of the State of New York, Respondent v. Joshua Washington, Appellant
June 14, 199586 N.Y.2d 189
Summary
The Court affirmed the Appellate Division's order refusing to vacate Joshua Washington's manslaughter conviction, holding that the audiotape made by an Associate Medical Examiner is not Rosario material because the People lack control over OCME documents. Justice Titone dissented, arguing that OCME functions as a law‑enforcement agency and its records should be subject to the Rosario disclosure rule.