Case Detail
CitationPeople v. Huston, 668 N.E.2d 1362 (N.Y. 1996)
Pros. First NameMatthew
Pros. Last NameMurphy, III
Trial YearUKN
BodySupreme court
OpinionOn grant of appeal, the New York Court of Appeals held that dismissal of the indictment was required because the prosecutor violated his duty of fair dealing by engaging in pervasive misconduct during grand jury proceedings which impaired integrity of such proceedings and may have prejudiced the defendant. "Because the prosecutor's misconduct was intentional, usurped the function of the Grand Jury and biased the proceedings against the defendant, it impaired the integrity of the Grand Jury proceedings and created a substantial risk of prejudice to the defendant. . . . The prosecutor again acted as an unsworn witness, usurping the fact-finding function of the Grand Jury, when he informed it of the inference it should draw from the fact that only a small amount of human blood was found on defendant's sneaker and jacket—the only physical evidence connecting defendant to the murders. Specifically, he informed questioning grand jurors that it was “not accurate” that, given the number of stab wounds, more blood should have been found on defendant's clothing. He further stated, “we've got no evidence to indicate and it's not accurate to assume that by the stab, the blood would splatter out and cover him.” Whether this physical evidence was sufficiently persuasive to warrant belief that defendant committed the crime, however, was a question reserved exclusively for the grand jurors. . . . Throughout his questioning of Jule Huston, moreover, the prosecutor communicated his disbelief in Huston's testimony to the Grand Jury. Although Jule Huston repeatedly denied that the bloody knife incident ever took place, the prosecutor continued to ask questions that assumed defendant did indeed appear at Huston's apartment with a bloody knife and admit to killing his wife and mother-in-law. While a prosecutor who believes a witness is not being forthright may vigorously question or press that witness, the prosecutor here simply went too far."
Determination Year1996
Misconduct TypePT: Evidence
Pre-Trial -- Other
C/S EffectDismissal
Pros. Misc. ReportedUKN
Sanction TypeUKN
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