People v. Hayes
17 N.Y.3d 46
| NY | 2011Background
- In the early morning of August 8, 2004, Charles Shell and 10 friends attended a 1:00 a.m. movie in a Times Square theater, where a confrontation with defendant Kenneth Hayes occurred.
- Shell testified that Hayes grabbed his wrist, punched him, and fled after a stabbing left Shell injured and bleeding.
- Defendant contends he acted to disarm Shell during an exchange and that Shell had earlier brandished a weapon; Shell was unarmed when Hayes allegedly stabbed him.
- Sergeant Fitzpatrick, guarding the crime scene, overheard two bystander statements about the knife and who had it but did not identify or contact the bystanders.
- During trial preparation, the People disclosed the statements to the defense, which argued a Brady violation and sought to use the statements to challenge the police investigation; the trial court limited cross-examination, and the Appellate Division affirmed the judgments.
- The Court affirms, holding no Brady violation but upholding the trial court’s limitation on cross-examination as within discretion under the circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady violation from failure to interview bystanders | Shell | Hayes | No Brady violation; no affirmative duty to obtain bystander contacts; disclosed content sufficed. |
| Right to challenge investigation via cross-examination (Kyles framework) | Hayes | Statements could show investigation lapses; cross-exam sought to test thoroughness | Trial court did not abuse discretion in limiting hearsay use; no due process violation. |
Key Cases Cited
- People v Alvarez, 70 N.Y.2d 375 (1987) (no duty to affirmatively gather evidence for the accused)
- People v Reedy, 70 N.Y.2d 826 (1987) (evidence not in possession need not be disclosed)
- Brady v. Maryland, 373 U.S. 83 (1963) (due process requires disclosure of favorable evidence)
- United States v Rodriguez, 496 F.3d 221 (2d Cir. 2007) (government not required to create notes for witnesses)
- Kyles v. Whitley, 514 U.S. 419 (1995) (defense may challenge investigation; not unlimited cross-examination rights)