What is the test for a waiver of indictment by a grand jury?

"New York", United States of America

The following excerpt is from People v. Myers, 109 N.E.3d 555, 32 N.Y.3d 18, 84 N.Y.S.3d 406 (N.Y. 2018):

A defendant's waiver of indictment by grand jury, like waivers of other fundamental rights, must be made knowingly, voluntarily, and intelligently (see People v. Weinberg , 34 N.Y.2d 429, 431, 358 N.Y.S.2d 357, 315 N.E.2d 434 [1974] ). It is the responsibility of the court to "make certain [of] a defendant's understanding of the waiver" and ensure "full appreciation of [its] consequences," though "a trial court need not engage in any particular litany or catechism in satisfying

[32 N.Y.3d 25]

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