A grand jury indicted one of Garrow's lawyers – Francis Belge, with whom he had shared the location of two victims' bodies – for violating §§ 4200(1) and 4143 of the New York Public Health Law: the first such section required that a decent burial be accorded the dead, while the second required "anyone knowing of the death of a person without medical attendance, to report the same to proper authorities. The trial court granted the attorneys' motion to dismiss the indictment on the grounds that the communications between Garrow and Belge as to the whereabouts of the bodies were protected by the attorney–client privilege, and "in the interests of justice." As to the privilege, the court held that Belge's professional duties prohibited him from revealing information that would incriminate his client, reasoning that the Fifth Amendment rights of criminal defendants against self-incrimination would be circumvented if "compulsory disclosure can be exacted through his attorney." However, the court noted that if Belge had been charged with obstruction of justice "under a proper statute," rather than a rarely applied "pseudo-criminal statute," the requisite balancing of the accused's Fifth Amendment rights against the rights of society to punish culpable behavior would have rendered the court's decision much more difficult.