People v. Huston

In People v. Huston, 88 NY2d 400 [1996], the New York State Court of Appeals set forth the responsibilities and critical functions of the Grand Jury, specifically it's obligation to investigate criminal activity and to protect individuals from unfounded prosecutions. The Court found that if the Grand Jury is improperly influenced, the integrity of Grand Jury proceedings is impaired. The Court stated that the New York State Legislature "requires that an indictment be dismissed where the Grand Jury proceeding is defective (see, CPL 210.20(1)(c)). Moreover, dismissal of the indictment is specifically compelled by statute when the integrity of the Grand Jury proceeding is impaired and prejudice to the defendant may result (see, CPL 210.35[5])" (see, Huston at 401). The issue evaluated by the Court of Appeals in Huston was whether prosecutorial misconduct in the Grand Jury proceeding rendered the indictment in that case fatally defective. The Court found that, "because the prosecutor's misconduct was intentional, usurped the function of the Grand Jury and biased the proceedings against the defendant, it impaired the integrity of the Grand Jury proceedings and created a substantial risk of prejudice to the defendant" (see, Huston at 402). The Court of Appeals dismissed the indictment.