| People v Santiago |
| 2015 NY Slip Op 50444(U) [47 Misc 3d 1205(A)] |
| Decided on March 31, 2015 |
| Supreme Court, Kings County |
| Miller, J. |
| Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. |
| As corrected in part through April 7, 2015; it will not be published in the printed Official Reports. |
The People of
the State of New York
against Jesus Santiago, Defendant. |
The defendant moves, pro se, to dismiss the indictment. Counsel for the defendant adopts the defendant's motion. The People oppose the defendant's application. For the reasons that follow the motion is denied.
An indictment need not mention the name of the defendant in each count so long as the indictment fulfills its statutory purpose of identifying the defendant and the charges to which he must answer. (People v Brothers 66 AD2d 954 [3d Dep't 1978]). "An indictment is sufficient if it identifies the charge against the defendant so that his conviction or acquittal will prevent a subsequent charge for the same offense, and if it notifies him of the nature and character of the crime charged so that he may prepare his defense." (People v Armlin, 6 NY2d 231, 234 [1959]). Indeed, there is no particular form constitutionally mandated for an indictment so long as the indictment affords a defendant (a) fair notice of the charges made against him; (b) allows him to prepare a defense; and (c) avoid subsequent attempts to retry him for the same crime or crimes. (People v Ray, 71 NY2d 849, 850 [1988]). Incorporation by reference is sufficient to put the defendant on notice of the charges alleged and the defendant's commission thereof. (People v McDuffie, 89 AD3d 1154 [3d Dep't], lv denied 19 NY3d 964 [2012]). Where the accused is identified in the caption as the sole defendant, the body of the indictment need not repeat the full [*2]name of the accused and may property incorporate the full name of the accused, by referencing the term "the defendant", even if alleging that the accused acted in concert with others. (People ex rel. Lewis v Graham, 57 AD3d 1508 [4th Dep't], lv denied 12 NY3d 705 [2009]).