People v Branch |
2014 NY Slip Op 51297(U) [44 Misc 3d 1224(A)] |
Decided on August 7, 2014 |
Criminal Court Of The City Of New York, Kings County |
Montelione, J. |
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. |
As corrected in part through January 13, 2016; it will not be published in the printed Official Reports. |
The People of
the State of New York
against David Branch, Defendant. |
Defendant moves to dismiss the accusatory instrument herein, pursuant to CPL § 170.30, as facially insufficient. For the reasons stated herein, Defendant's motion to dismiss the count alleging violation of VTL § 511(1)(a) is granted. Although not included in Defendant's Notice of Motion, his papers also contain an argument that certain statements he allegedly made be precluded because of the People's failure to provide timely notice pursuant to CPL § 710.30(1)(a). Although the preclusion argument is now moot with regard to the VTL § 511(1)(a) charge, because the Court's file notations show that statement notice was served and filed at arraignment, and the file contains a copy of such notice, there were never any grounds to seek such relief for that charge. To the extent the argument to dismiss was considered regarding the remaining VTL 509(1) charge, it is denied.
PROCEDURAL BACKGROUNDIn the afternoon of January 12, 2014, the arresting officer responded to the scene of an accident. Defendant allegedly was one of the drivers involved in the accident. The arresting officer ran a computer check of the Department of Motor Vehicles ("DMV") driving records and learned that Defendant's driving privileges had been suspended for failure to pay child support. Defendant was arrested and charged with violating VTL § 509(1) (Unlicensed Operator, a violation) and VTL § 511(1)(a) (Aggravated Unlicensed Operation of a Motor Vehicle in the Third Degree, an unclassified misdemeanor).
RELEVANT STATUTESVTL § 509(1) provides "no person shall operate or drive a motor vehicle upon a public highway of this state . . . unless he is duly licensed pursuant to the provisions of this chapter." A violation of this section is not a crime, and is punishable by "a fine of not less than seventy-five [*2]nor more than three hundred dollars, or by imprisonment for not more than fifteen days. . . ." VTL § 509(11).
A violation of VTL § 511(1)(a), however, is an unclassified misdemeanor. A violation of the section has a mandatory punishment set forth in VTL § 511(1)(b): "(i) a fine of not less than two hundred dollars nor more than five hundred dollars, or (ii) a term of imprisonment of not more than thirty days, or (iii) both such fine and imprisonment."
Because of these increased, and mandatory, punishments, the law places a greater burden on the prosecution to charge and prove a case under VTL § 511(1)(a) than under VTL § 509(1). VTL 511(1)(a) provides:
CPL § 100.40 provides, in relevant part, that an information is sufficient on its face when the "[n]on-hearsay allegations of the factual part of the information and/or of any supporting depositions establish, if true, every element of the offense charged and the defendant's commission thereof." CPL § 100.40(1)(c).
At arraignment, the People filed a complaint sworn to by the arresting officer. In it, the officer avers (1) that his check of the DMV records showed that Defendant's license had been suspended for failure to pay child support, and (2) that the DMV mails a notice of suspension to "any such person at their last known address." The People also filed a copy of Defendant's driving record abstract. That abstract reflects that Defendant's driver's license had been suspended on May 6, 2011, for failure to pay child support.
The abstract contains the following certification:
Although at first blush, it may appear that requiring non-hearsay evidence that a defendant "knew" of a suspension imposes an impossible burden of showing "scienter" before conversion, the statutory standard of "knowing or having reason to know" about the suspension is an objective standard.
Both sides direct the Court to VTL § 214 and lines of cases interpreting that section. VTL § 214 may provide assistance in determining whether the scienter requirement of VTL § 511(1)(a) has been satisfied. VTL § 214 provides:
A number of courts have specifically approved this procedure at the pleading stage to convert a complaint into an information. People v. J.T., 13 Misc 3d 1212(A) (Crim. Ct. NY County 2006); People v. Pabon, 167 Misc 2d 214 (Crim. Ct. Bronx County 1995); People v. Garcia, 163 Misc 2d 862, (Crim. Ct. Bronx County 1989). See also, People v. Meyer, 177 Misc 2d 537 (App. Term. 2d Dept. 1998). Although this leaves open the question of whether the People must use this or some other procedure to properly plead scienter, the People must always provide non-hearsay evidence (or evidence which is an exception to the hearsay rule) regarding whether the defendant knew or "should have known" his or her license had been suspended, e.g., an admission by defendant, a plea taken in open court, or correspondence sent to defendant showing notice of suspension. This is because non-hearsay evidence that defendant "should have known" of a suspension will always provide an inference that defendant knew of the suspension, which satisfies whatever scienter requirement is needed for conversion.
Cases Holding Scienter Is A Trial IssueSome reported cases hold that a complaint charging VTL § 511(1) will be properly converted as long as the driving abstract shows that the defendant's license had been suspended. Essentially, these cases leave the scienter element as a matter of proof to be made at trial.
For example, in People v. Gabriel, 164 Misc 2d 473 (Crim. Ct. Queens County 1995), the court found that "the defendant's knowledge that his privilege to drive had been suspended is a question of fact at the time of trial and the satisfaction of Vehicle and Traffic Law § 214 is not a prerequisite for the conversion of a misdemeanor complaint to an information." Id. at 476. This case supports the contention that scienter need only be established at trial, and need not be supported by non-hearsay at the pleading stage.
In People v. Etienne, 192 Misc 2d 90 (Dist. Ct. Nassau County 2002), followed Gabriel, supra. The Etienne court held that:
In one of the few appellate decisions discussing the appropriate pleading standard for cases arising under VTL § 511(1)(a), the Appellate Term, Second Department held that because all traffic summonses contain a warning that "If you don't answer this ticket by mail within 15 days your license will be suspended," an allegation that the arresting officer conducted a check of DMV records and learned that the defendant's license had been suspended for failure to answer or appear in response a traffic summons was sufficient to satisfy the non-hearsay requirement of CPL § 100.40. People v. Benitez, 44 Misc 3d 129(A) (App. Term, 2d Dept. 2014). Benitez involved a license suspended for failure to answer a traffic summons that on its face noted failure to do so would necessarily engender a license suspension. The Appellate Term did not, however, address the situation where a license was suspended for a reason other than failure to respond to a traffic summons.
Cases Holding That Scienter Must Be Alleged and Supported in the InformationOther cases hold that VTL § 214, while it provides a way for the prosecution to establish a presumption of scienter at trial, does not relieve the People of providing non-hearsay allegations regarding scienter in an information.
For example, in People v. Carlsons, 171 Misc 2d 943 (Sup. Ct. Nassau County 1997), the court reviewed grand jury minutes, and permitted the case to proceed on several of the charges against the defendant. However, it dismissed the charge of violation of VTL § 511(1) because in support of that charge, the district attorney had submitted only a driving abstract. The court held that
In People v. J.T., 13 Misc 3d 1212(A) (Crim. Ct. NY County 2006), the court dismissed the VTL § 511(1)(a) charge against the defendant. The court noted that the "resolution of the [*3]motion turns on whether the documents submitted by the People are sufficient to corroborate the allegation in the complaint that defendant knew or had reason to know his license to drive had been suspended or revoked, which is an essential element of aggravated unlicensed operation." The court held that the abstract alone could not satisfy the scienter requirement but noted that it was not placing an undue burden on the People:
In People v. Brown, 15 Misc 3d 1143 (A) (Crim. Ct. NY County 2007), defendant Gonzalez was charged with violating VTL § 511(1). On facts very much like those in the case at bar, the complaint alleged that a computer check by the arresting officer had revealed that defendant Gonzalez's license had been suspended for failure to pay child support. The complaint alleged that the DMV sends a notice prior to suspending a license for failure to pay child support. The court held, however, that "these allegations, while providing reasonable cause to believe that defendant had reason to know of the suspension, are nevertheless hearsay, and thus insufficient." Id. The court, therefore, dismissed the charges because no affidavit or documentation was provided showing that the notice had been mailed to the defendant.
People v. Acevedo, 27 Misc 3d 889 (Crim. Ct. NY County 2010) appears to be on all fours with the case at bar. In Acevedo, the defendant's license had been suspended for failure to pay child support. The court held:
The Court is not persuaded by the cases cited by the People. In its view, those cases turn primarily on convenience to the prosecution. For example, in Etienne, the court noted "[t]ypically, Vehicle and Traffic Law § 511(2)(a)(iv) misdemeanor informations are dismissed because the scienter element is too burdensome to prove for purposes of conversion." 192 Misc 2d at 95. See also, People v. Gabriel, 164 Misc 2d 473 (Crim. Ct. Queens County 1995).
On the other hand, the Court agrees completely with the holding in People v. Acevedo, supra. Unlike a suspension that follows from failure to respond to a traffic summons, a suspension for failure to pay child support depends on procedures of the DMV that are not within the personal knowledge of an arresting officer.
In short, the Court finds that the complaint herein contains only hearsay allegations regarding Defendant's knowledge whether his license had been suspended. As such, it is facially insufficient to plead a violation of VTL § 511(1)(a).
RICHARD J. MONTELIONE,
Judge, Criminal Court