The People of the State of New York, Respondent v. Robert C. Ryan, Appellant

Summary

The Court held that the term "knowingly" in Penal Law § 220.18(5) applies to the weight element, requiring mens rea for the amount of a hallucinogen; it found the evidence insufficient to prove the defendant's knowledge of that weight and therefore reversed the conviction, allowing prosecution only on the lesser‑included seventh‑degree offense; it also reversed the trial court's denial of the defendant's request to proceed pro se, finding no waiver and improper basis for denial.