People v. Edwards (Jaquan)
2025 NY Slip Op 50632(U)
N.Y. App. Term.2025Background
- Jaquan Edwards pleaded guilty to common-law driving while intoxicated (DWI) in Kings County, New York.
- Edwards waived the right to be prosecuted by information and pleaded guilty before Judge Warin; he was sentenced by Judge Walsh.
- The accusatory instrument cited Edwards' admission to operating a vehicle while intoxicated and stated his location at 1666 Union Street, Kings County.
- On appeal, Edwards argued the accusatory instrument was facially insufficient, as it did not adequately allege operation of a motor vehicle or that the conduct occurred on a public highway/open road.
- The prosecution maintained that the evidentiary allegations, including Edwards' admission and arrest location, sufficiently supported the charge under misdemeanor complaint standards.
- The court reviewed the sufficiency of the accusatory instrument under the standards relevant for misdemeanor complaints, due to Edwards' explicit waiver of prosecution by information.
Issues
| Issue | Edwards' Argument | State's Argument | Held |
|---|---|---|---|
| Facial sufficiency of accusatory instrument for DWI | Instrument failed to state facts showing Edwards operated a vehicle on a public highway or private road open to traffic | Edwards' admission and details in the complaint establish operation and location, meeting evidentiary requirements | Sufficient; the conviction is affirmed |
Key Cases Cited
- People v. Case, 42 N.Y.2d 98 (jurisdictional prerequisites for criminal prosecution)
- People v. Dreyden, 15 N.Y.3d 100 (facial insufficiency is a jurisdictional defect)
- People v. Suber, 19 N.Y.3d 247 (corroboration of admission not required for prima facie case)