New York Court of Appeals

The People of the State of New York, Respondent v. Jose Rodriguez, Appellant

December 19, 200095 N.Y.2d 497

Summary

The New York Court of Appeals held that a trial court is not obligated to consider pro se speedy‑trial motions filed by a defendant who is represented by counsel, as the decision lies within the trial judge’s discretion. The Court also reversed the defendant’s robbery conviction because the admission of a lineup identification obtained without counsel was not harmless beyond a reasonable doubt. The case was remanded for further proceedings.