People v. Brewer

OPINION OF THE COURT

David Friedman, J.

In People v Chase (85 NY2d 493) the Court of Appeals modified a long-standing rule on spontaneous statements. In such decision the Court held that, where a defendant has made a statement to a law enforcement agent, the People are required to provide him with CPL 710.30 (1) (a) notice even though the statement was spontaneously made. The issue presented here is whether Chase has also expanded the notice requirement of *949CPL 710.30 to require notice of a statement made by a defendant in custody to a private person which is overheard by a police officer. I…