finding after a preliminary hearing (New York) · Go Syfert
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finding after a preliminary hearing in New York

12 New York opinions name it 1 courts 1996–2026 5 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
People v. Barbergreen
nyappdiv · 2001 · cited in 7 New York opinions naming this issue, 2006–2021
2 sentences

2021"Being so 'held' for the action of a [g]rand [j]ury involves the filing of a felony complaint on which defendant has been arraigned and a finding after a preliminary hearing (unless waived by defendant) that reasonable cause exists to believe that defendant committed a felony" ( People v Barber , 280 AD2d 691, 692 [3d Dept 2001], lv denied 96 NY2d 825 [2001]; see People v D'Amico , 76 NY2d 877, 879 [1990]).

2021"Being so 'held' for the action of a [g]rand [j]ury involves the filing of a felony complaint on which defendant has been arraigned and a finding after a preliminary hearing (unless waived by defendant) that reasonable cause exists to believe that defendant committed a felony" ( People v Barber , 280 AD2d 691, 692 [3d Dept 2001], lv denied 96 NY2d 825 [2001]; see People v D'Amico , 76 NY2d 877, 879 [1990]).

77
People v. D'Amicogreen
ny · 1990 · cited in 6 New York opinions naming this issue, 2001–2026
2 sentences

2026"Being so held for the action of a [g]rand [j]ury involves the filing of a felony complaint on which defendant has been arraigned and a finding after a preliminary hearing (unless waived by defendant) that reasonable cause exists to believe that defendant committed a felony" ( Price , 195 AD3d at 1571 [internal quotation marks omitted]; see People v D ' Amico , 76 NY2d 877, 879 [1990]).

2021"Being so 'held' for the action of a [g]rand [j]ury involves the filing of a felony complaint on which defendant has been arraigned and a finding after a preliminary hearing (unless waived by defendant) that reasonable cause exists to believe that defendant committed a felony" ( People v Barber , 280 AD2d 691, 692 [3d Dept 2001], lv denied 96 NY2d 825 [2001]; see People v D'Amico , 76 NY2d 877, 879 [1990]).

66
People v. Gassnergreen
nyappdiv · 2021 · cited in 2 New York opinions naming this issue, 2021–2021
2 sentences

2021Here, despite the absence of an order issued by the court, the record establishes that defendant was properly held for the action of a grand jury inasmuch as defendant acknowledged that he received the felony complaint upon which he was arraigned and waived his right to a preliminary hearing ( see People v Gassner , — AD3d &mdash, &mdash, 2021 NY Slip Op 02192, *1 [3d Dept 2021]; Anderson , 149 AD3d at 767 ), and the court immediately transferred over the case from its capacity as the local criminal court to its capacity as County Court ( see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018],

2021Here, despite the absence of an order issued by the court, the record establishes that defendant was properly held for the action of a grand jury inasmuch as defendant acknowledged that he received the felony complaint upon which he was arraigned and waived his right to a preliminary hearing ( see People v Gassner , 193 AD3d 1182, 1184 [3d Dept 2021]; Anderson , 149 AD3d at 767 ), and the court immediately transferred over the case from its capacity as the local criminal court to its capacity as County Court ( see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018], lv denied 31 NY3d 1081 [2018]

22
People v. Davenportgreen
nyappdiv · 2013 · cited in 2 New York opinions naming this issue, 2021–2021
2 sentences

2021Here, despite the absence of an order issued by the court, the record establishes that defendant was properly held for the action of a grand jury inasmuch as defendant acknowledged that he received the felony complaint upon which he was arraigned and waived his right to a preliminary hearing ( see People v Gassner , — AD3d &mdash, &mdash, 2021 NY Slip Op 02192, *1 [3d Dept 2021]; Anderson , 149 AD3d at 767 ), and the court immediately transferred over the case from its capacity as the local criminal court to its capacity as County Court ( see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018],

2021Here, despite the absence of an order issued by the court, the record establishes that defendant was properly held for the action of a grand jury inasmuch as defendant acknowledged that he received the felony complaint upon which he was arraigned and waived his right to a preliminary hearing ( see People v Gassner , 193 AD3d 1182, 1184 [3d Dept 2021]; Anderson , 149 AD3d at 767 ), and the court immediately transferred over the case from its capacity as the local criminal court to its capacity as County Court ( see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018], lv denied 31 NY3d 1081 [2018]

22
People v. Pricegreen
nyappdiv · 2021 · cited in 1 New York opinions naming this issue, 2026–2026
2 sentences

2026"Being so held for the action of a [g]rand [j]ury involves the filing of a felony complaint on which defendant has been arraigned and a finding after a preliminary hearing (unless waived by defendant) that reasonable cause exists to believe that defendant committed a felony" ( Price , 195 AD3d at 1571 [internal quotation marks omitted]; see People v D ' Amico , 76 NY2d 877, 879 [1990]).

2026Where, as here, a court sitting in a hybrid capacity transfers the case from its capacity as a local criminal court to its capacity as Supreme Court, the court "thereby effectively order[s] defendant held for grand jury action" ( People v Cicio , 157 AD3d 651 , 651 [1st Dept 2018], lv denied 31 NY3d 982 [2018]; see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018], lv denied 31 NY3d 1081 [2018]; see generally Price , 195 AD3d at 1571 ).

11
People v. Valentigreen
nyappdiv · 1999 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010Here, petitioner was arraigned upon the two felony complaints and waived a preliminary hearing, the matter was transferred to County Court, and County Court approved petitioner’s waiver of indictment upon a finding that it complied with the requirements of CPL article 190 (see People v Barber, 280 AD2d at 692 ; People v Valenti, 264 AD2d 904, 905 [1999], lv denied 94 NY2d 926 [2000]).

11
People v. Mitchellgreen
nyappdiv · 1997 · cited in 1 New York opinions naming this issue, 2008–2008
1 sentence

2008As this Court has stated, “[i]n practical terms, this means that a defendant must be arrested and arraigned in a local criminal court prior to executing the waiver” (People v Mitchell, 235 AD2d 834, 835 [1997], lv denied 89 NY2d 1038 [1997]).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
People v. Cambridge green
nycterr · 2018
2 sentences

2026Where, as here, a court sitting in a hybrid capacity transfers the case from its capacity as a local criminal court to its capacity as Supreme Court, the court "thereby effectively order[s] defendant held for grand jury action" ( People v Cicio , 157 AD3d 651 , 651 [1st Dept 2018], lv denied 31 NY3d 982 [2018]; see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018], lv denied 31 NY3d 1081 [2018]; see generally Price , 195 AD3d at 1571 ).

2021Here, despite the absence of an order issued by the court, the record establishes that defendant was properly held for the action of a grand jury inasmuch as defendant acknowledged that he received the felony complaint upon which he was arraigned and waived his right to a preliminary hearing ( see People v Gassner , — AD3d &mdash, &mdash, 2021 NY Slip Op 02192, *1 [3d Dept 2021]; Anderson , 149 AD3d at 767 ), and the court immediately transferred over the case from its capacity as the local criminal court to its capacity as County Court ( see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018],

32021–2026
People v. Menchetti green
ny · 1990
2 sentences

2024CPL 195.20 provides, in pertinent part that "[a] waiver of indictment shall be evidenced by a written instrument" that designates "each offense to be charged in the information." "The offenses named [in the SCI] may include any offense for which the defendant was held for action of a grand jury and any offense or offenses properly joinable therewith pursuant to sections 200.20 and 200.40." A person is "held for the action of a grand jury" with regard to an offense if the offense is charged in a felony complaint on which the person has been arraigned, and there has been a finding after a prelim

2024CPL 195.20 provides, in pertinent part that "[a] waiver of indictment shall be evidenced by a written instrument" that designates "each offense to be charged in the information." "The offenses named [in the SCI] may include any offense for which the defendant was held for action of a grand jury and any offense or offenses properly joinable therewith pursuant to sections 200.20 and 200.40." A person is "held for the action of a grand jury" with regard to an offense if the offense is charged in a felony complaint on which the person has been arraigned, and there has been a finding after a prelim

22024–2024
People v. Clark green
nycterr · 2019
2 sentences

2024CPL 195.20 provides, in pertinent part that "[a] waiver of indictment shall be evidenced by a written instrument" that designates "each offense to be charged in the information." "The offenses named [in the SCI] may include any offense for which the defendant was held for action of a grand jury and any offense or offenses properly joinable therewith pursuant to sections 200.20 and 200.40." A person is "held for the action of a grand jury" with regard to an offense if the offense is charged in a felony complaint on which the person has been arraigned, and there has been a finding after a prelim

2024CPL 195.20 provides, in pertinent part that "[a] waiver of indictment shall be evidenced by a written instrument" that designates "each offense to be charged in the information." "The offenses named [in the SCI] may include any offense for which the defendant was held for action of a grand jury and any offense or offenses properly joinable therewith pursuant to sections 200.20 and 200.40." A person is "held for the action of a grand jury" with regard to an offense if the offense is charged in a felony complaint on which the person has been arraigned, and there has been a finding after a prelim

22024–2024
People v. Anderson green
nyappdiv · 2017
2 sentences

2021Here, despite the absence of an order issued by the court, the record establishes that defendant was properly held for the action of a grand jury inasmuch as defendant acknowledged that he received the felony complaint upon which he was arraigned and waived his right to a preliminary hearing ( see People v Gassner , — AD3d &mdash, &mdash, 2021 NY Slip Op 02192, *1 [3d Dept 2021]; Anderson , 149 AD3d at 767 ), and the court immediately transferred over the case from its capacity as the local criminal court to its capacity as County Court ( see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018],

2021Here, despite the absence of an order issued by the court, the record establishes that defendant was properly held for the action of a grand jury inasmuch as defendant acknowledged that he received the felony complaint upon which he was arraigned and waived his right to a preliminary hearing ( see People v Gassner , 193 AD3d 1182, 1184 [3d Dept 2021]; Anderson , 149 AD3d at 767 ), and the court immediately transferred over the case from its capacity as the local criminal court to its capacity as County Court ( see People v Fox , 158 AD3d 591 , 591 [1st Dept 2018], lv denied 31 NY3d 1081 [2018]

22021–2021
People v. Gallagher green
nyappdiv · 2006
1 sentence

2010“Being so ‘held’ for the action of a [g]rand Q]ury involves the filing of a felony complaint on which [the] defendant has been arraigned and a finding after a preliminary hearing (unless waived by [the] defendant) that reasonable cause ex ists to believe that [the] defendant committed a felony” (People v Barber, 280 AD2d 691, 692 [2001], lv denied 96 NY2d 825 [2001] ; see CPL 180.70; People v D’Amico, 76 NY2d 877, 879 [1990]; People v Gallagher, 34 AD3d 941 , 942 [2006], lv denied 8 NY3d 880 [2007]).

12010–2010
People v. Talham green
nyappdiv · 1973
1 sentence

2001While it is undisputed here that the local criminal court never issued an order holding defendant over for ac tion by the Grand Jury or transmitted such an order to County Court with the required documentation, although required by CPL 180.30 (1) and 180.70 (1), such noncompliance is not a jurisdictional defect requiring nullification of defendant’s waiver or plea (see, People v Talham, 41 AD2d 354, 356 ).

12001–2001
People v. Zanghi green
ny · 1991
1 sentence

1996Under the circumstances of this case, defendant’s reliance upon People v Zanghi ( 79 NY2d 815 ) is misplaced.

11996–1996

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