People v. Branton (2025): Defining the Outer Limits of CPL 245.20 – Why DOCCS Is Not “Under the Prosecution’s Control” for Automatic Discovery

Introduction

In People v. Branton, 238 A.D.3d 1429 (3d Dep’t 2025), the Appellate Division confronted a mosaic of post-reform criminal procedure questions: the scope of automatic discovery under CPL 245.20, speedy-trial calculations under CPL 30.30, and the perennial Miranda custody analysis.

Rodney Branton, a self-described “sovereign citizen,” filed baseless liens against the Acting Commissioner of Corrections and two judges. He was indicted for offering a false instrument for filing in the first degree but was ultimately convicted by a jury of the lesser second-degree count and sentenced to nine months. On appeal he raised four principal challenges: (1) evidentiary weight, (2) invalidity of the prosecution’s Certificate of Compliance (COC) for failing to obtain Department of Corrections and Community Supervision (DOCCS) disciplinary records, (3) violation of the six-month speedy-trial rule, and (4) suppression of statements to a DOCCS investigator.

The Third Department affirmed in full, but in doing so supplied two clarifying rules of statewide importance:

DOCCS is neither a “law-enforcement agency acting on the government’s behalf in the case” nor otherwise within the prosecution’s “possession, custody or control” for CPL 245.20 purposes. Therefore its personnel records lie outside automatic discovery obligations and need not be obtained for a valid COC.
Time consumed by a defendant’s request for judicial reassignment is excludable from the CPL 30.30 speedy-trial clock, even when the People remain otherwise inactive.

Summary of the Judgment

Justice Aarons, writing for a unanimous panel, held:

Weight of the Evidence: The jury reasonably inferred Branton’s knowledge of falsity from his own admissions and the complete absence of any legitimate debt.
Automatic Discovery: Because DOCCS is not under prosecutorial control, its disciplinary files are outside the People’s constructive possession; failure to obtain them does not invalidate a COC.
Speedy Trial: Forty-five days attributable to Branton’s requests for new judges were properly excluded, bringing the People within the 184-day limit.
Suppression: The bedroom interview was non-custodial; Miranda warnings were unnecessary and the statements admissible.

Analysis

A. Precedents Cited

People v. Kelly, 88 N.Y.2d 248 (1996) – Earlier discovery regime holding that DOCS (now DOCCS) disciplinary records are beyond constructive possession; the Branton court extends this rationale into the CPL 245 framework.
People v. Walker, 232 A.D.3d 1214 (4th Dep’t 2024) – Reiterated Kelly; Branton relies on it for inter-departmental consistency.
People v. Contompasis, 236 A.D.3d 138 (3d Dep’t 2025) – Explained the “due diligence” obligation; Branton distinguishes due diligence as unnecessary when the agency is categorically outside the statute.
People v. Kopciowski, 68 N.Y.2d 615 (1986) – Core authority on excludable time where delay is occasioned by the defendant.
People v. Robbins, 236 A.D.3d 1097 (3d Dep’t 2025) and People v. Davis, 196 A.D.3d 918 (3d Dep’t 2021) – Mirrored custody factors guiding the Miranda analysis.

B. Legal Reasoning

Automatic Discovery

CPL 245.20(1)(k)(iv) requires the People to disclose impeachment material that is “in the possession, custody or control of the prosecution or persons under the prosecution’s direction or control, including … police or other law-enforcement agencies acting on the government’s behalf in the case.”

Branton urged that DOCCS investigators, akin to police, fall under this umbrella. The court disagreed, anchoring its reasoning in Kelly’s structural distinction between custodial authorities and law-enforcement agencies. The panel emphasized that the 2020 discovery reforms (CPL 245) did not redefine DOCCS’s status; absent statutory change, DOCCS remains outside prosecutorial dominion. Accordingly, disciplinary records—no matter how useful for impeachment—are not automatically discoverable unless actually possessed by the prosecutor.

Because the information was outside mandatory discovery, the validity of the COC was unaffected and no “due diligence” inquiry was required. This represents a notable boundary-drawing exercise: while CPL 245 dramatically broadened discovery, it did not obliterate the agency-possession requirement.
Speedy-Trial Computation

The People declared readiness eight days beyond the nominal 184-day window. However, 45 days were excludable under CPL 30.30(4)(a), (b), and (g) because they resulted from Branton’s explicit requests for new judges after refusing to waive potential conflicts. The panel treated these requests as “administrative delays” occasioned by defendant, squarely within Kopciowski.

Significantly, the court implicitly held that no “prosecutorial neglect” test applies where the defendant affirmatively instigates the delay; mere prosecutorial inaction during the reassignment process does not convert the period into chargeable time.
Miranda/Custody

Applying the “reasonable, innocent person” standard, the court concluded that the bedroom interview lacked the coercive hallmarks of custody: no restraint, short duration, cooperative atmosphere, and the defendant’s freedom to move.

C. Impact

The decision resonates in three distinct arenas:

Discovery Litigation – Branton is the first appellate opinion to apply Kelly’s DOCS rationale to the post-2020 discovery statute. Prosecutors statewide can rely on Branton to resist demands for DOCCS personnel files unless they have actually procured them.
Speedy-Trial Strategy – Defense attorneys must now weigh the tactical cost of requesting new judges; such motions generally toll the CPL 30.30 clock.
Sovereign-Citizen Liens – By affirming the sufficiency/weight of evidence, the court fortifies the use of “paper terrorism” filings as a prosecutable offense and clarifies that subjective beliefs in “sovereignty” do not negate the element of knowledge.

Complex Concepts Simplified

Automatic Discovery / CPL 245.20 – A 2020 statute compelling prosecutors to hand over most evidence within 20 or 35 days. It is broader than the old “Brady/Giglio” regime but still limited to materials the prosecution actually controls.
Certificate of Compliance (COC) – A sworn statement filed by the People declaring that they have fulfilled their CPL 245 obligations; without it, the case cannot proceed to trial.
Constructive Possession – A legal fiction that deems the prosecutor to “possess” materials held by agencies working on the case, even if the DA never physically receives them.
Excludable Time (CPL 30.30) – Periods that do not count against the People’s readiness window, such as delays caused by the defendant.
Miranda Custody – The situation in which a reasonable person would feel they are not free to leave; only then must police provide Miranda warnings before interrogation.

Conclusion

People v. Branton crystallizes two jurisprudential guideposts for the post-reform era. First, the universe of “law-enforcement” agencies under CPL 245.20 does not automatically expand to every governmental body that employs investigators; DOCCS remains outside, and its internal disciplinary records remain undiscoverable absent actual possession. Second, a defendant cannot manufacture speedy-trial delay by requesting serial recusals and then blame the prosecution for lost time.

Beyond its doctrinal contributions, Branton underscores a practical reality: even sweeping procedural reforms have limits, and courts will enforce them to guard against gamesmanship on both sides of the aisle. Practitioners should adjust discovery demands and speedy-trial calculations accordingly, while sovereign-citizen litigants are reminded that filing fictitious liens invites criminal liability.