The People v. Michael Bay

Summary

The Court held that a certificate of compliance is proper only when the prosecution has exercised due diligence and made reasonable inquiries to identify mandatory discovery before filing it. Because the People failed to establish that they had done so, their certificate was improper and their statement of trial readiness was illusory, requiring dismissal under the speedy-trial statute without a showing of prejudice. The Court reversed the order below, granted Bay’s dismissal motion, and dismissed the accusatory instrument.