ESQ HQNEW YORK LAW WATCH

Appellate Division, Third Department · October 1, 2026 · 2026 NY Slip Op 05573

People v Miller

Read the official decision: 2026 NY Slip Op 05573

Holding The court affirmed the conviction, holding that the People satisfied their disclosure obligations under CPL 245.20 by providing a summary of the detective’s disciplinary history rather than full files, as the omitted details did not tend to impeach credibility. Additionally, the court found that the defendant’s statements were voluntary despite the use of leg restraints, and that the trial court properly determined the defendant was competent to stand trial and correctly denied a missing witness charge.

The court’s words

the People undisputedly disclosed the source and full content of th[e] allegations before filing

2026 NY Slip Op 05573, at the official text

the use of restraints is not determinative of whether a defendant's statements were voluntary or involuntary

2026 NY Slip Op 05573, at the official text

the court found that the People had established that the charge was not appropriate because the victim was unavailable

2026 NY Slip Op 05573, at the official text

we cannot conclude that the court abused its discretion in finding defendant was not an incapacitated person

2026 NY Slip Op 05573, at the official text
CourtAppellate Division, Third Department
DecidedOctober 1, 2026
Citation2026 NY Slip Op 05573
Area of lawCriminal Law
WeekWeek ending October 3, 2026
Official textOfficial decision: 2026 NY Slip Op 05573
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id751
Related recordsPeople v Miller, 2026 NY Slip Op 04615; People v Miller, 2026 NY Slip Op 04614

Recommended citation

ESQ HQ, New York Law Watch, People v Miller, 2026 NY Slip Op 05573 (Appellate Division, Third Department, October 1, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05573/

How this record was made

Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.

Read how Law Watch works

Published October 1, 2026. Updated October 1, 2026.