People v. Matos
2025 NY Slip Op 50353(U)
Kings Criminal Ct.2025Background
- Feliciano Matos was charged with aggravated unlicensed operation of a motor vehicle in the third degree (a misdemeanor), unlicensed operation (violation), and failing to yield to a pedestrian with resulting injury (misdemeanor).
- Matos moved to dismiss on the grounds of invalid Certificate of Compliance (COC) with discovery obligations and violation of speedy trial rules (CPL 30.30 and 170.30(1)(e)).
- The COC and Statement of Readiness (SOR) were filed by the prosecution 59 days after arraignment; the applicable statutory limit is 60 days given the top charges are misdemeanors.
- Defense argued key discovery materials were missing: an ambulance call report (ACR), an aided card, EMS personnel information, and a full photo of the complainant’s injury.
- The prosecution responded that it exercised due diligence: the aided card did not exist, the ACR and EMS info are not subject to automatic discovery, and the requested photo was turned over promptly after receipt.
- The court evaluated whether the COC was invalid due to alleged discovery failures and whether speedy trial time limitations were exceeded.
Issues
| Issue | Matos's Argument | People's Argument | Held |
|---|---|---|---|
| COC validity—missing ACR, aided card, EMS info | COC invalid without these items | Not subject to automatic discovery or do not exist; due diligence exercised | Absence of these does not invalidate COC |
| Belated disclosure of full injury photo | Late production makes COC invalid | Photo provided immediately after it was received; due diligence shown | No effect on COC validity; due diligence and prompt response shown |
| Speedy Trial (CPL 30.30) compliance | More than 60 days elapsed without valid readiness | Only 59 days accrued; readiness announced timely with valid COC | Speedy trial rule not violated; less than 60 days elapsed |
| Duty to obtain and produce outside agency items | Required to subpoena and provide such records | Not required to obtain by subpoena information defense can independently obtain | Not required for COC; obligations satisfied |
Key Cases Cited
- People v. Beasley, 16 NY3d 289 (defining burden on defendant for CPL 30.30 dismissal motions)
- People v. Cooper, 98 NY2d 541 (explaining calculation of speedy trial periods by top count and commencement date)
- People v. Bay, 41 NY3d 200 (certificate of compliance must precede declaration of readiness)
- People v. Chavis, 91 NY2d 500 (clarifying first-day exclusion in statutory day calculation)
- People v. Stiles, 70 NY2d 765 (application of first-day exclusion in speedy trial context)