New York Court of Appeals
The People of the State of New York, Respondent v. Lesly Joseph, Appellant
October 31, 199586 N.Y.2d 565
Summary
The Court held that a police document that has been destroyed cannot be considered the "duplicative equivalent" of a disclosed Rosario material, so the People violated the Rosario disclosure rule and the trial court erred by refusing an adverse‑inference instruction; the conviction was reversed and a new trial ordered. The decision also notes dissenting judges who argued that no prejudice was shown.