New York Court of Appeals

The People of the State of New York, Respondent v. Steven L. Swamp, Appellant

January 10, 199584 N.Y.2d 725

Summary

The Court affirmed that a Grand Jury may rely on a trained officer's testimony about a Scott‑Reagent field test to establish a prima facie case of cocaine possession without a formal laboratory report. The majority held the indictment was legally sufficient, while a dissent argued the field test alone was insufficient and would reverse the appellate decision.