People v. Paul

In People v. Paul, 133 Misc 2d 234 (Crim.Ct. NY Co.1986) the court held that "a complaint is facially sufficient if an officer states that a defendant possessed a substance which, because of his training and experience, the officer concluded was narcotics. There is no requirement that the complaint contain a description of the officer's training and experience." In so holding, however, the court specifically noted that "the court will require, ..., especially in cases where the complaint charges possession of a controlled substance other than marijuana, a laboratory report in order to convert the complaint to an information.