The People of the State of New York v. Antonio Vilardi

Summary

The Court affirmed the Appellate Division’s order vacating the defendant’s first‑degree arson conviction and granting a new trial, holding that New York’s materiality standard for undisclosed exculpatory evidence in cases where the defense made a specific request is the “reasonable possibility” test, not the federal Bagley “reasonable probability” standard. Justice Simons, in a separate concurrence, argued that the Bagley standard should be adopted.