The People of the State of New York v. Jimmy Martinez

Summary

The New York Court of Appeals affirmed the Appellate Division’s order, holding that the trial court properly denied the defendant’s motion to preclude the principal witness’s testimony and correctly imposed an adverse‑inference sanction for the State’s failure to produce Rosario material. The Court found that any prejudice to the defendant was remote because the description had been broadcast and a tape was disclosed, and therefore the trial court’s discretionary sanction was appropriate.