People v Rinzler

Holding The court affirmed the judgment, holding that the defendant’s guilty plea foreclosed his challenge to the sufficiency of the grand jury evidence. The court also determined that the indictment was not jurisdictionally defective because the counts incorporated the applicable statutory provisions.

The court’s words

a particular count in an indictment is jurisdictionally defective only if it does not effectively charge the defendant with the commission of a particular crime

2026 NY Slip Op 06039, at the official text

incorporate[ ] by reference the statutory provision applicable to the crime intended to be charged, this is sufficient to apprise a defendant of the charge

2026 NY Slip Op 06039, at the official text

the alleged deficiency concerns the quantum of proof before the grand jury and is therefore fundamentally inconsistent with his guilty plea

2026 NY Slip Op 06039, at the official text

defendant's guilty plea forecloses his assertion that the evidence presented to the grand jury was not legally sufficient

2026 NY Slip Op 06039, at the official text