Occasionally, a court decision forces law enforcement to dramatically alter its methods of fighting crime. Such a scenario recently occurred based on a decision by a four-judge panel of the Appellate Division, Second Department, in People v. Kozlow, 31 AD3d 788 (July 25, 2006).
In a unanimous opinion, the court interpreted the meaning of the word “depicts” as it appears in the statute that criminalizes first-degree disseminating indecent material to minors (Penal Law �235.22). The ruling held that “depicts” applies only to the transmission of sexually explicit pictures over a computer communications system such as the Internet.
