NEW YORK CITY, NY – A Manhattan judge found that prosecutors made a significant disclosure error involving an NYPD Internal Affairs Bureau log, but declined to invalidate their trial-readiness filing after concluding that the mistake reflected a misunderstanding rather than an effort to hide evidence.
In People v Paul, the defense challenged the prosecution’s certificate of compliance and statement of readiness. The defense said prosecutors had not provided several categories of potential discovery, including Internal Affairs logs, Civilian Complaint Review Board histories, disclosure indexes or notices for two officers, and medical records.
New York’s discovery law requires prosecutors to exercise due diligence and make reasonable inquiries for material in the possession, custody or control of the prosecution team. A valid certificate of compliance is central to whether the prosecution can declare readiness for trial.
The Manhattan Criminal Court found a concrete problem in the record. One Internal Affairs log was already in the possession of the prosecution team when an assistant district attorney certified that the office had been unable to obtain it.
The court described that certification as a significant error. That finding matters because police disciplinary and misconduct material can bear directly on an officer’s credibility, a defendant’s ability to test the government’s proof and the fairness of plea or trial decisions.
But the judge did not find attempted withholding. Looking at the totality of the circumstances, the court concluded that prosecutors had acted with due diligence and in good faith. The certificate remained valid, and the defense motion was denied.
That result draws a line between a serious discovery mistake and a certificate that is legally invalid. The ruling shows that identifying an omitted item does not automatically end the inquiry. Courts also examine what prosecutors did to locate the material, what they understood when they certified compliance and whether the overall process was reasonable.
The decision does not erase the underlying error. It puts renewed attention on how information moves between the NYPD, Internal Affairs and prosecutors. When one part of the prosecution team possesses a record while another says it cannot be obtained, the breakdown can limit meaningful defense review and invite litigation over trial readiness.
The opinion also highlights the stakes of police-accountability records. Internal Affairs and CCRB materials are not administrative trivia. Depending on their contents and the role of the officers involved, they may help a defense lawyer investigate credibility, bias, prior conduct or the reliability of police testimony.
The court’s ruling was procedural, not a determination of guilt or innocence. The defense allegations about missing discovery were tested under the statutory compliance standard. The judge upheld the certificate and denied the requested relief, allowing the prosecution to continue relying on its readiness filing.
Unanswered questions remain. The ruling does not establish whether agencies have changed their exchange procedures since the error, whether automated checks could have identified the IAB record before certification, or how often similar mismatches occur without reaching a written decision.
For everyday New Yorkers, the accountability issue is larger than one file. Discovery reform depends on prosecutors and police maintaining systems that can find and disclose required material accurately. Good faith may protect a filing in a particular case, but it does not eliminate the need to repair a process that produced a significant false statement about what the prosecution team possessed.
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