People State New York v. Jeffrey Young

In this case, the Appellate Division relied on what it perceived to be the "commonsense limits" of the Rosario rule as a basis for affirming a conviction notwithstanding the prosecutions failure to disclose an "unusual occurrence report." The issue is whether the report contained statements of a trial witness that would constitute Rosario material. Defendants appeal also requires us to consider whether a "commonsense" exception to the Rosario-Consolazio-Jones doctrine should be recognized when the reviewing court deems the information in the undisclosed putative Rosario material too insubstantial or trivial to warrant the reversal of a conviction.