People v. Griffin

In People v. Griffin (137 AD2d 558 [2d Dept 1988]), defendant and a codefendant were charged in an indictment with robbery. Additionally, the codefendant was charged in a separate indictment with robbing the same victim of additional property moments after the first robbery. The indictments were consolidated for trial and the court found the consolidation of the two indictments was proper under CPL 200.40 (1) (c), holding that the two offenses constituted the same "criminal transaction." The Court stated that the determination as to whether or not the two robberies were a part of the same criminal transaction required that the Court examine "the nature of the crime, as well as the underlying facts (i.e., victim, time, place and date)" (People v. Griffin, supra at 559).