People v. Miller
2025 NY Slip Op 50907(U)
| N.Y. Sup. Kings | 2025Background
- Steven Miller was indicted for attempted murder and related crimes after allegedly shooting the complainant during a robbery on January 1, 2024.
- The complainant received medical treatment at two hospitals: Interfaith Medical Center (IMC) and Brookdale University Hospital (BUH).
- The district attorney timely subpoenaed and disclosed IMC records, but did not initially subpoena BUH records.
- Defense moved pretrial to dismiss the indictment, arguing the DA failed to comply with statutory discovery requirements by not obtaining all medical records before stating readiness for trial.
- The court reviewed all relevant discovery efforts, including subsequent subpoenas and disclosures, and all procedural adjournments and delays.
- The court ultimately determined whether the district attorney’s certificate of discovery compliance (CoC) was valid, and whether the speedy trial clock had expired under CPL 30.30.
Issues
| Issue | Miller’s Argument | People’s Argument | Held |
|---|---|---|---|
| Whether DA had to subpoena all medical records before CoC | DA must subpoena and ensure completeness of all records | Not required to subpoena material the defense can obtain | Not required; DA met statutory obligations |
| Whether partial discovery compliance invalidates readiness | CoC invalid with missing BUH records; readiness was illusory | DA disclosed what was in possession; defense could seek | Statement of readiness is valid given disclosures made |
| If defense was unable to obtain records due to HIPAA | Defense unable to subpoena records without complainant waiver | HIPAA allows judicial orders/subpoenas for disclosure | Defense can obtain records via so-ordered subpoenas |
| If enough speedy trial time elapsed to require dismissal | DA’s noncompliance means trial clock should run | Most delays are excludable, clock not exceeded | Only 81 days chargeable; dismissal motion denied |
Key Cases Cited
- People v Osgood, 52 NY2d 37 (NY Ct. App. 1980) (sets timeline for speedy trial calculation)
- People v England, 84 NY2d 1 (NY Ct. App. 1994) (illusory statement of readiness is insufficient to toll the speedy trial clock)
- People v Brown, 28 NY3d 392 (NY Ct. App. 2016) (burden shifting framework for excluding trial delay days)
- People v Cortes, 80 NY2d 201 (NY Ct. App. 1992) (sets procedure for speedy trial day computation)
- People v Bay, 41 NY3d 200 (NY Ct. App. 2023) (discovery compliance needed before valid readiness declaration)