The People of the State of New York, Respondent v. Dennis P. Smalls, Appellant

Summary

The New York Court of Appeals affirmed the Appellate Division, holding that the misdemeanor information alleging the defendant possessed burnt drug residue was facially sufficient to constitute a prima facie case of seventh-degree criminal possession of a controlled substance. The Court applied the heightened pleading standards for an information and found the officer’s training and description adequate.