People v. South

In People v. South (41 NY2d 451 [1977]), the Court of Appeals held that a judge must render the verdict within a reasonable time and "what will be 'reasonable' must, of course, turn largely on the circumstances of the individual case." Noting that the matter before it was an assault in the third degree case involving a fight between schoolboys, the Court of Appeals stated, inter alia: "No complicated issues of fact were presented; no evidentiary questions remained to be resolved; there were no contested propositions of law; no posttrial submissions were sought or offered" (id.). In these circumstances, the Court concluded "as a matter of law, that the delay of 58 days was unreasonable in this case. (Cf. People v. O'Brien, 86 Misc 2d 139 [conviction of disorderly conduct in Village Court set aside where verdict by Village Justice was returned 35 days after the conclusion of the trial])" (41 NY2d at 455).