Important developments on other matters are noted including decisions concerning accusatory instruments, grand jury procedure, joinder and severance, speedy trial, double jeopardy, discovery, guilty pleas, and competence to stand trial. Trial procedure decisions focus on right to counsel, jury trial, and confrontation. Other matters, such as admissibility of scientific evidence, hearsay issues, corroboration requirements, and expert testimony, are briefly noted. Regarding post-trial procedure, the Supreme Court announced a due process rule forbidding judicial vindictiveness in sentencing. In a number of cases, the Court of Appeals rejected defendants' claims that they were improperly denied permission to file supplemental pro se briefs. 281 notes