The People of the State of New York v. Dayshawn P. Handy

Summary

The New York Court of Appeals reversed the Appellate Division’s affirmation of the defendant’s conviction and ordered a new trial. It held that when a defendant, with due diligence, requests evidence that is likely material and the State destroys that evidence, a permissive adverse‑inference instruction must be given. The Court declined to require dismissal of the indictment, finding the adverse inference sufficient to remedy the due‑process violation.