New York Vehicle and Traffic Law 306 (b) Example Case
In People v. Rosado (192 Misc 2d 184, 746 NYS2d 565 (Crim Ct, NY County 2002), the court dismissed a complaint for facial insufficiency where it was alleged that the safety emission inspection certificate on the defendant's vehicle was a forgery without any other allegations from which defendant's knowledge of the forgery could be inferred.
In that case, the information only alleged that it was the "defendant's vehicle" (at 185), but did not contain allegations as to the defendant's ownership, operation or physical relationship to the vehicle.
Although there was a statutory requirement pursuant to Vehicle and Traffic Law 306 (b) to display an inspection certificate before parking or operating a vehicle, the court held that "defendant's apparent failure to comply with this duty, without more, failed to establish circumstantially his knowledge of the forged nature of the certificate" (id. at 186).