The People of the State of New York, Respondent v. Philip D’Angelo, Appellant

Summary

The New York Court of Appeals affirmed the Appellate Division's order, holding that the indictment for criminal contempt second degree was not jurisdictionally defective despite omitting the labor‑dispute exemption language. The Court reiterated that an indictment must allege all material elements of the crime, and that this requirement applies regardless of plea negotiations or the timing of the challenge.