PEOPLE v. RICHARDS (2020)

Judgment of conviction (Laurence E. Busching, J.), rendered November 20, 2018, affirmed.

Since defendant waived prosecution by information, the accusatory instrument only had to satisfy the reasonable cause requirement of a misdemeanor complaint (see People v. Dumay, 23 NY3d 518, 522 [2014]). So viewed, the accusatory instrument was jurisdictionally valid because it described facts of an evidentiary nature establishing reasonable cause to believe that defendant was guilty of obstructing governmental administration in the second degree (see Penal Law § 195.05). The instrument alleges that defendant, an inmate at Riker's Iskand, punched Corrections Officer Steve Kissoon in the face, causing swelling and redness to his jaw, as well as substantial pain, and forcing him to leave his assigned post. A reasonable person could infer from these facts that when defendant punched the officer, he intended to prevent the officer from performing his official duties (see People v. Dumay at 525).

In view of our disposition, we reach no other issue.

Per Curiam.

All concur.