Does a police officer's observation of metal knuckles constitute a jurisdictional defect?

factual allegations of an item of contraband, such as an illegal drug or weapon, we have held that the conclusory description of the contraband is a jurisdictional defect (see People v. Dumas , 68 N.Y.2d 729, 731, 506 N.Y.S.2d 319, 497 N.E.2d 686 [1986] ; Kalin , 12 N.Y.3d at 229, 878 N.Y.S.2d 653, 906 N.E.2d 381 ). Specifically, the conclusory allegations are considered insufficient to satisfy "the requirement for factual allegations of an evidentiary character" ( 68 N.Y.2d at 731, 506 N.Y.S.2d 319, 497 N.E.2d 686 ).

Here, defendant waived prosecution by information, and our review is limited to reviewing the sufficiency of the misdemeanor complaint under the reasonable cause standard (see Kalin , 12 N.Y.3d at 229, 878 N.Y.S.2d 653, 906 N.E.2d 381 ).² In People v. Dreyden , although we observed that "[t]he distinction between jurisdictional and nonjurisdictional defects is between defects implicating the integrity of the process ... and less fundamental flaws, such as evidentiary or technical matters, " we held that the arresting officer's conclusory allegations that the weapon in defendant's possession was a gravity knife was a "violation of the reasonable cause requirement amount[ing] to a jurisdictional

[139 N.E.3d 369]

defect" ( 15 N.Y.3d at 103, 905 N.Y.S.2d 542, 931 N.E.2d 526, quoting People v. Hansen , 95 N.Y.2d 227, 231, 715 N.Y.S.2d 369, 738 N.E.2d 773 [2000] ). On the other hand, in Aragon , we held that the officer's observation of metal knuckles an object

[115 N.Y.S.3d 748]