New York City Human Resources Administration v. Carey
This case concerns a CPLR article 78 petition in the nature of a writ of prohibition. The petitioner, the City Human Resources Administration (HRA), sought to vacate a Supreme Court order regarding defendant Delgado, who was charged with arson. Delgado was found by two psychiatrists to be an incapacitated person unable to stand trial due to a severe hearing defect. The lower court, misinterpreting CPL article 730, ruled that Delgado's physical incapacity did not fall under the statute and ordered his placement with HRA and the Department of Social Services. The appellate court granted the writ of prohibition, vacating the lower court's order for exceeding its jurisdiction. The court declared Delgado incompetent to stand trial *nunc pro tunc* and committed him to the custody of the New York State Commissioner of Mental Health, clarifying that CPL 730.10 broadly applies to any mental defect causing incapacity, regardless of its source. The decision emphasized that the statute does not distinguish between different sources of disability once a finding of incapacity is made.