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. The decision rests on the distinction that OCME is not a law‑enforcement agency subject to the prosecutor's control. A dissent argued the opposite, contending that OCME functions as a law‑enforcement entity and its records should be disclosed.