Automatic Impeachment Disclosure & Speedy Trial Compliance under CPL 245: Establishing Obligations in People v. Coley

Introduction

People v. Coley (2025 NYSlipOp 01945) is a landmark Second Department decision that clarifies the scope of the prosecution’s new automatic discovery obligations under CPL 245.20(1)(k)(iv) and the interplay of those obligations with the speedy-trial deadlines of CPL 30.30. Arising from charges that Derrick Coley and three co-defendants possessed a loaded firearm in Queens County, the appeal centers on whether the People timely disclosed material capable of impeaching a key police witness—Lieutenant Ramiro Ruiz—whose credibility had previously been rejected in an unrelated suppression hearing. The Supreme Court granted the defendants’ motions to dismiss for violation of their six-month CPL 30.30 speedy-trial right, and the Appellate Division affirmed.

Key issues:

The breadth of “all evidence and information … that tends to impeach the credibility of a testifying prosecution witness” under CPL 245.20(1)(k)(iv).
Whether disciplinary records and a hearing transcript from an unrelated case in which Lt. Ruiz was found incredible must be disclosed as “related to the subject matter of the case.”
How non-compliance with CPL 245 automatic-discovery rules affects the validity of certificates of compliance (COCs) and statements of trial readiness under CPL 30.30.

Summary of the Judgment

The Appellate Division held that:

Under CPL 245.20(1)(k)(iv), “all evidence and information” tending to impeach a prosecution witness is automatically discoverable if it relates to the witness’s credibility, regardless of its connection to the charged offense.
The People were required to disclose the underlying records (including transcripts and the appellate decision) from People v. Harris, where Lt. Ruiz’s testimony had been found “not credible” by an Appellate Division panel.
Because the People failed to produce those materials before filing their certificates of compliance on August 17, September 19, and December 6, 2022, none of the COCs were valid and their statements of readiness were illusory.
The delay prior to valid readiness exceeded six months, so the indictments were dismissed under CPL 30.30.
The order dismissing the indictment was affirmed.

Analysis

Precedents Cited

Brady v. Maryland (373 U.S. 83 [1963]): Established the prosecution’s duty to disclose exculpatory evidence material to guilt or punishment. People v. Coley notes that CPL 245.20 expands beyond Brady’s “materiality” requirement to mandatory disclosure of all impeachment information.
People v. Bay (41 NY3d 200 [2023]): Interpreted the 2019 reforms linking CPL 245 discovery to CPL 30.30 speedy-trial compliance and emphasized the broad “automatic” disclosure regime.
People v. Harris (192 AD3d 151 [2d Dept. 2021]): Found Lt. Ruiz’s testimony in a suppression hearing “not credible” and rejected his account of visual observations during a traffic stop.
People v. Smith (27 NY3d 652 [2016]): Reinforced that impeachment material need not be tied to the defendant’s case facts if it bears on a witness’s credibility.
People v. McCarty (221 AD3d 1360 [4th Dept. 2023]): Held that subsequent diligent disclosures will not cure an earlier invalid COC, highlighting the importance of timely initial compliance.

Legal Reasoning

1. Statutory Text and Legislative Intent
CPL 245.20(1) mandates that the prosecution disclose “all items and information that relate to the subject matter of the case,” and CPL 245.20(1)(k)(iv) specifically covers “all evidence and information … that tends to impeach the credibility of a testifying prosecution witness.” The court emphasized the plain meaning: the Legislature omitted any qualifier limiting impeachment discovery to the facts underlying the charges, signaling an intent to require broad access to credibility-related material.

2. Presumption of Openness
CPL 245.20(7) codifies a “presumption in favor of disclosure.” Restrictive readings of “subject matter” that would exclude impeachment evidence from unrelated proceedings cannot stand in light of the statute’s remedial and transparency-focused purpose.

3. Good Faith Certificate of Compliance & CPL 30.30
Under CPL 245.50(1), a certificate of compliance must confirm that “after exercising due diligence” the People have disclosed “all known material and information subject to discovery.” CPL 30.30(5) then ties statements of readiness to a valid COC. Because underlying records of Harris were neither turned over nor the People’s efforts documented, no COC was valid and no readiness declaration stopped the speedy-trial clock.

4. Impact of Delay
The court calculated 242 days chargeable to the People—well beyond the six-month limit. The failure to timely disclose impeachment materials thus mandated dismissal.

Impact

People v. Coley has major repercussions:

Defense Access to Impeachment Material: Prosecution must affirmatively seek and produce transcripts, decisions, and records from any proceeding that might impeach a witness’s credibility—even if those proceedings are wholly unrelated to the defendant’s case.
Rigorous COC Requirements: Certificates of compliance must be supported by documentary proof of diligent inquiry and timely disclosure. Post-certification disclosures cannot retroactively validate an invalid COC.
Trial-Calendar Pressure: Prosecutors will face heightened urgency to gather and produce broad categories of evidence before filing readiness statements, or risk dismissal.
Broader Discovery Culture: Reinforces the 2019 reforms aimed at transparency, leveling the playing field, and fostering informed plea decisions or trial strategies.

Complex Concepts Simplified

“All Evidence and Information”: Means exactly that—any record, transcript, or document that could undercut a witness’s truthfulness.
“Subject Matter of the Case”: In the context of impeachment, it encompasses anything relevant to a witness’s credibility, not just the charged acts.
Certificate of Compliance (COC): A sworn declaration that the People, after reasonable effort, have turned over every discoverable item.
Statement of Readiness: A formal indication that the prosecution is prepared for trial. It must be backed by a valid COC under CPL 30.30.
Speedy Trial Clock: Under CPL 30.30(1)(a), a felony defendant must be tried within six months of arraignment unless valid exclusions apply.

Conclusion

People v. Coley cements a robust automatic-discovery regime in New York criminal practice. By interpreting CPL 245.20(1)(k)(iv) to require disclosure of all impeachment-related records—regardless of their connection to the charged offense—the court has underscored the legislative commitment to transparency and fairness. Prosecutors must now build discovery protocols that capture past credibility challenges to their witnesses, obtain transcripts and appellate decisions, and document their efforts before filing any certificate of compliance. Failure to do so will expose cases to dismissal under the strict speedy-trial framework of CPL 30.30. In the broader landscape, Coley advances equal access to information for defendants, fosters more informed plea discussions, and strengthens the integrity of jury verdicts.