People v. Autorino

Due process requires that a citizen accused of misconduct be given fair notice ‘ ‘ of the nature of the charge against him and of the act constituting it ’ (People v. Zambounis, 251 N. Y. 94, 96 [1929].) In this case, the interesting question is presented whether due process is satisfied by a simplified complaint that in its entirety describes the charge as follows: “ Lewd Act. No Pasties GoGo.”

The use of a simplified summons and complaint for nontraffic offenses is permitted by rule X of the Rules of the Criminal Court of the City of New York. (22 NYCRR 2950.10.) The draftsmen of the rule…