New York Court of Appeals
The People of the State of New York v. Dana Jones
November 25, 198770 N.Y.2d 547
Summary
The Court affirmed the Appellate Division's reversal, holding that a total failure to turn over Rosario‑required witness statements is per se error that cannot be subjected to harmless error analysis. The decision rests on the principle that only defense counsel can assess the impeachment value of such material, making speculation by the reviewing court impermissible.