New York Court of Appeals

The People of the State of New York v. Patrick Lawrence

December 27, 198464 N.Y.2d 200

Summary

The Court affirmed the Appellate Division, holding that a defendant may not defer a motion to dismiss on speedy‑trial grounds until after a guilty verdict; such motions must be made in writing before trial or a plea of guilty. The dissent argued that the statute permits discretionary consideration of the motion after trial and would have reversed.