New York Court of Appeals
The People of the State of New York, Respondent v. Christopher Allen, Appellants
October 22, 199892 N.Y.2d 378
Summary
The Court held that the solicitation exemption under Penal Law § 100.20 applies to the 54 defendants because their conduct was necessarily incidental to a marijuana sale, thus barring prosecution, and affirmed that the accusatory instruments were sufficiently pleaded. Justice Bellacosa concurred in the result but on a narrower basis, warning against a broader reading of the exemption.