New York Court of Appeals

The People of the State of New York v. Tashiem Bayard

November 17, 201015 N.Y.3d 896

Summary

The Court affirmed the Appellate Division’s order, holding that the People’s failure to disclose the identity of the officer who prepared the police omniform system complaint report did not constitute a Brady violation. The Court reasoned that even assuming the omitted name had exculpatory or impeachment value, there was no reasonable possibility that the trial’s outcome would have been different, and the trial court had already permitted the defense to use the unsigned report and other evidence.