New York Court of Appeals
The People of the State of New York v. Phillip Goggins, Respondent the People of the State of New York v. Robert Brown
May 15, 197434 N.Y.2d 163
Summary
The New York Court of Appeals affirmed the appellate division orders in People v. Goggins and People v. Brown, holding that disclosure of an informant’s identity is required when the informant’s role is material to the defendant’s guilt and the case presents a genuine issue of fact, but not when the informant’s involvement is merely peripheral and the prosecution’s identification is reliable. The court emphasized that such disclosure must occur in a full adversarial hearing rather than ex parte. Justice Jasen dissented, arguing that the majority erred in requiring disclosure in Goggins.