The People of the State of New York, Respondent v. Lesly Joseph, Appellant

Summary

The Court held that a police document that has been destroyed cannot be deemed the "duplicative equivalent" of previously disclosed Rosario material, that the trial court abused its discretion by refusing to give the jury an adverse‑inference instruction, and therefore reversed the Appellate Division’s order and remanded for a new trial. The decision was contested by a dissenting opinion urging legislative reform of Rosario discovery.