People v. Bonie
This case involves an appeal by nonparty News 12 The Bronx, L.L.C., and its representative Dina Sforza, against an order compelling compliance with a subpoena for unaired video footage. The People sought the footage from an interview with defendant Nasean Bonie, who was indicted for the murder of Ramona Moore. The Supreme Court, Bronx County, initially granted the People's motion to compel, directing an in camera review and denying News 12's cross-motion to quash the subpoena. The Appellate Division, First Department, modified this order. It directed disclosure only of specific portions of the video footage where Bonie discusses killing the victim or their relationship, finding that the People met the necessary showing under New York's Shield Law for these parts, and otherwise affirmed the lower court's decision. The court clarified that the trial judge need not issue further findings.