People v. Wilson

In People v Wilson (234 AD2d 986), the Appellate Division, Fourth Department, stated that the term "encompasses only information relating to a specific criminal transaction," although it did not provide any definition of the term "criminal transaction." In the Wilson case, the issue before the Court was the legal sufficiency of the proof at trial. There, the proof established that defendant saw a confidential informant sitting in the back seat of a police car and he shouted at him that he had seen him, that he was working with the police and that he was " 'going to get' " what was coming to him (supra, at 987). Defendant continued to follow the informant and police car and shouted that the informant was not going to be able to continue to live in that community. There was additional proof that the threats placed the informant in fear for his safety. The Appellate Division reversed defendant's conviction and held that the statute was "not intended to protect from intimidation persons who may obtain knowledge about potential future criminal activity" (supra, at 987). Rather, it had to involve specific information about a crime.