Monday, November 4, 2013

People v. Vilardi case brief

People v. Vilardi case brief summary
76 N.Y.2d 67 (1990)

Appellant prosecution sought review of a decision of the Appellate Division of the Supreme Court in the Second Judicial Department (New York), which granted defendant's motion to vacate his judgment of conviction for the offenses of arson in the first degree, reckless endangerment in the first degree, attempted arson in the first degree, conspiracy in the second degree, and conspiracy in the fourth degree.

Defendant was convicted of various arson crimes. He challenged his conviction, contending that he was entitled to a new trial because the prosecution improperly withheld exculpatory evidence from his defense counsel. The lower court granted his motion for a new trial. The prosecution challenged the decision, contending that the motion was improper because it should have been raised on direct appeal.

  • The court rejected the prosecution's contention, finding that defendant was entitled to a new trial because there was a reasonable possibility the exculpatory evidence that had not been disclosed contributed to defendant's conviction. 
  • The court ruled that the evidence was material because it was a report that the a bomb had never exploded. 
  • The court noted that other defendants associated with the same crime were acquitted.


The court affirmed the lower court's decision granting defendant a new trial. The court held that there was a reasonable probability that the undisclosed evidence might have led to a different trial strategy that would have resulted in a different outcome.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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