New York Court of Appeals

The People of the State of New York, Respondent v. Johnson Edwards, Appellant

December 19, 200095 N.Y.2d 486

Summary

The Court held that People v. Darden creates a mandatory requirement for an in‑camera examination of a confidential informant when the informant’s testimony is essential to establish probable cause. Accordingly, the trial court’s refusal to hold such a hearing was erroneous, and the case was remanded for a Darden hearing. The decision also clarified that the defendant need not make a threshold showing to obtain the hearing.