In People v Dumas (68 NY2d 729 [1986]), the defendant was charged with the sale and possession of marijuana. The lower court had dismissed the complaint as legally insufficient; however, the Appellate Term had reversed and reinstated the complaint. The Court of Appeals reversed the Appellate Term and reinstated the dismissal. The Court of Appeals held that the Criminal Court complaint failed to show the basis for the officer's belief that the substance sold and recovered was in fact marijuana, and contained "no allegation that the police officer is an expert in identifying marihuana." (Id. at 731.) The Court of Appeals held that in order for an accusatory instrument to sufficiently allege a marijuana offense, evidentiary facts must be pleaded that show the basis for the conclusion that a substance consisted of marijuana. A field or laboratory test, an officer's expertise in identifying marijuana, or a defendant's admission may provide the requisite corroboration. (Id. at 731.) The Court of Appeals held that misdemeanor complaints alleging the criminal sale and/or possession of marihuana are facially insufficient where they contain a conclusory statement that each defendant sold marihuana but fail to support that statement with evidentiary facts showing the basis for the conclusion that the substance sold (and/or possessed) was actually marihuana, since the factual part of a misdemeanor complaint must allege facts of an evidentiary character (CPL 100.15 [3]) demonstrating reasonable cause to believe the defendant committed the crime charged (CPL 100.40 [4] [b]).