People v. Morales
Opinion of the Court
— Order of the Supreme Court, Bronx County (Frank Torres, J.), dated September 20, 1990, which granted defendant’s motion to dismiss the indictment, is unanimously reversed on the law and the indictment reinstated.
On the night of April 14, 1986, as Reinaldo Mejias was leaving the building at 1915 Andrews Avenue in the Bronx, he heard three shots. He observed defendant Jose Morales, with whom he was acquainted from the neighborhood, standing approximately twenty feet away from him. Defendant was not far behind Rogelio Rodriguez, who was staggering and appeared to be dizzy. Mejias noticed defendant placing what "looked like a gun” inside his coat. There was no one else in the vicinity. Defendant fled the scene, and Mejias chased after him into the building but was unable to locate him. Then,
Defendant was indicted for murder in the second degree and criminal possession of a weapon in the second degree. In granting the motion to dismiss the indictment, the Supreme Court observed that "[w]hile 'a Grand Jury need not be instructed with the same degree of precision that is required when a petit jury is instructed on the law,’ People v. Calbud, Inc., 49 NY2d 389, 394; the district attorney must provide 'the Grand Jury with enough information to enable it intelligently to decide whether a crime has been committed and to determine whether there exists legally sufficient evidence to establish the material elements of the crime,’ ibid, p. 395. The court finds the circumstantial evidence instruction is legally insufficient to inform the Grand Jury so that it might intelligently make a decision as to whether or not to indict the defendant.” This was error. Defendant’s motion to dismiss the indictment should have been denied. In that regard, the Court of Appeals in People v Calbud, Inc. (49 NY2d 389, 394-395, supra) stated, in considering the distinction between the role of a grand jury and that of a petit jury, that: "Given this functional difference between the two bodies, it would be unsound to measure the adequacy of the legal instructions given to the Grand Jury by the same standards that are utilized in assessing a trial court’s instructions to a petit jury. Indeed, the difference in the extent and quality of the legal instructions that must be given to the two bodies is reflected
Although the Supreme Court recognized the principle underscored in People v Calbud, Inc. (supra; and reaffirmed in People v Valles, 62 NY2d 36; People v Goetz, 68 NY2d 96; People v Darby, 75 NY2d 449), it nonetheless found the District Attorney’s charge to the grand jury to have been deficient. Since circumstantial evidence was correctly explained, the court presumably believed that a more comprehensive instruction was necessary. However, there is no legal requirement that the prosecution deliver any particular charge to a grand jury. According to CPL 190.30 (7), "[wjhenever it is provided in article sixty that a court presiding at a jury trial must instruct the jury with respect to the significance, legal effect or evaluation of evidence, the district attorney, in an equivalent situation in a grand jury proceeding, may so instruct the grand jury”. Similarly, the failure to instruct the grand jury is not one of the grounds listed as authorizing dismissal of the indictment. At most, subdivision (5) of CPL 210.35, which is the catchall provision for a motion to dismiss an indictment, merely declares that a grand jury proceeding is defective when it "otherwise fails to conform to the requirements of article one hundred ninety to such degree that the integrity thereof is impaired and prejudice to the defendant may result.”
Considering the fact that even at trial a circumstantial evidence charge is mandated only where the proof is entirely circumstantial (see, People v Silva, 69 NY2d 858; People v Schermerhorn, 125 AD2d 729), the failure to furnish such an
Case-law data current through December 31, 2025. Source: CourtListener bulk data.