Due process requires that a citizen accused of misconduct be given fair notice "of the nature of the charge against him and of the act constituting it". (People v. Zambounis, 251 N.Y. 94, 96 [1929].) In this case, the interesting question is presented whether due process is satisfied by a simplified complaint that in its entirety describes the charge as follows: "Lewd Act. No Pasties GoGo."
The use of a simplified summons...
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