People v. Alexis Rodriguez

CourtNew York Court of Appeals
DecidedApril 2, 2019
Docket59 Â SSM 2
StatusPublished

This text of People v. Alexis Rodriguez (People v. Alexis Rodriguez) is published on Counsel Stack Legal Research, covering New York Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Alexis Rodriguez, (N.Y. 2019).

Opinion

State of New York MEMORANDUM Court of Appeals This memorandum is uncorrected and subject to revision before publication in the New York Reports.

No. 59 SSM 2 The People &c., Respondent, v. Alexis Rodriguez, Appellant.

Submitted by Paul J. Connolly, for appellant. Submitted by Peter Willis, for respondent.

MEMORANDUM:

The order of the Appellate Division should be affirmed. As part of a plea agreement

and in exchange for a favorable sentence, defendant entered into a written cooperation

agreement whereby he promised to “cooperate completely and truthfully with law

-1- -2- SSM No. 2

enforcement authorities, including the police and the District Attorney’s Office, on all

matters in which his cooperation is requested, including but not limited to the prosecution

of [defendant’s accomplices] on charges related to the murder of Jose Sanchez and the

assault of [Sanchez’s brother].” Prior to entering into the cooperation agreement,

defendant had confessed to his involvement in the Sanchez murder and assault, explaining

that the crimes were retaliation for a prior invasion of defendant’s home by Sanchez and

his associates, including Jose Marin. When defendant signed the agreement, he already

had testified to Marin’s involvement in the home invasion before the grand jury in the

Sanchez matter, and he also had assisted the police with their investigation of the home

invasion by identifying Marin in a photo array.

The cooperation agreement cautioned defendant that a “fail[ure] to fully and

successfully cooperate” would result in forfeiture of the sentencing promise and imposition

of an enhanced sentence. Before County Court accepted his guilty plea, defendant

confirmed on the record that he understood this aspect of the cooperation agreement.

Defendant pleaded guilty to murder and assault, and he was subsequently sentenced on the

murder count. Upon consent of the parties, sentencing on the assault count was postponed

until defendant had fulfilled his obligations under the cooperation agreement. Before

imposition of that sentence, the District Attorney’s Office requested that defendant testify

against Marin in connection with the prosecution of the home invasion. Defendant refused.

On this record, County Court did not err when it determined that defendant’s refusal

to testify against Marin violated the express terms of his cooperation agreement. The plain

language of the agreement was objectively susceptible to but one interpretation (see People

-2- -3- SSM No. 2

v Cataldo, 39 NY2d 578, 580 [1976]). County Court, therefore, did not abuse its discretion

by denying defendant’s motion to withdraw his guilty plea based on his claimed subjective

misinterpretation of the agreement or by concluding, to the contrary, that defendant

reasonably understood that his cooperation in the Marin prosecution was required (see id.;

see also People v Collier, 22 NY3d 429, 433 [2013]). Defendant’s ineffective assistance

of counsel argument likewise lacks merit (see People v Manor, 27 NY3d 1012, 1014

[2016]).

-3- People v Alexis Rodriguez

SSM No. 2

RIVERA, J. (dissenting):

This appeal presents an open question that this Court has never addressed: what

interpretive standards apply to the terms of a cooperation agreement when, as here, a

defendant claims to have neither intended nor understood the agreement to include the

People’s demand for assistance with an unspecified criminal investigation or prosecution?

Rather than tackle that issue head on, the majority affirms the Appellate Division’s order

in a single sentence analysis that is short on reasoning and creates confusion in this

undeveloped area. Our constitutional role is to provide guidance to our State’s courts and

bar by providing clear rules of legal analysis. In the case of cooperation agreements, those

bargained-for-promises are subject to our traditional rules of contract interpretation.

Applying those rules here, I conclude that defendant’s cooperation agreement is limited in

scope to the crimes for which he pleaded guilty. Therefore, defendant did not violate the

agreement when he refused to testify against an individual charged with a different, prior

crime against defendant and his family. Accordingly, it was error for County Court to deny

defendant’s motion to withdraw his guilty plea upon that court’s refusal to sentence

defendant to the consecutive terms he bargained for. I dissent.1

I.

1 Defendant stresses that “[t]his appeal presents issues concerning the construction of plea agreements, by which the overwhelming majority of criminal prosecutions in this state are resolved,” that it specifically raises the important issue of how a court is to construe a cooperation agreement that purports to require a defendant’s unlimited cooperation, and that resolution of these issues is of especially great significance to defendant since it determines whether he serves 20 years to life or 40 years to life in prison. To that end, defendant objects to placement of his appeal on our alternative review track (see Rules of Ct of Appeals [22 NYCRR] § 500.11 [b]). As I have previously stated, once a majority of the Court chooses to maintain the appeal on the SSM track, notwithstanding a party’s objection, we must consider the issues in the posture presented (see Matter of Luis P., 32 NY3d 1165, 1167 n 2 [2018] [Rivera, J., dissenting]). For the reasons I discuss in this dissent, based on the record and the SSM letter submissions, I would reverse the Appellate Division. -2- -3- SSM No. 2

The Cooperation Agreement, Defendant’s Sentence and the Motion to Withdraw his

Guilty Plea

Defendant Alexis Rodriguez and his family were victims of a home invasion

burglary arising from a dispute between defendant and Jose Sanchez. Defendant owed

money to Sanchez for his help registering and insuring a minivan. Sanchez and three

accomplices — Sanchez’s two brothers and a man later identified as Victor Marin —

entered defendant’s home and brandished weapons at defendant and his family. Defendant

told the men to take the minivan in place of the money he owed, which they did. Before

leaving, Marin threatened defendant and his family that anyone who reported the incident

to the police would be killed.

About a month later, defendant and three accomplices armed with guns went to

Sanchez’s house intending to retrieve the vehicle. A fight ensued, during which defendant’s

accomplices fought and stabbed one of Sanchez’s brothers. One of the accomplices then

stabbed Sanchez, another shot him multiple times, and after Sanchez fell to the ground,

defendant shot Sanchez several more times.

Defendant was arrested for Sanchez’s murder and the stabbing and beating of

Sanchez’s brother. Defendant confessed and told the police about the home invasion to

explain the motive for his crimes. The People offered a plea bargain to defendant that

required his cooperation with law enforcement. During the negotiations but before signing

a written agreement, defendant was shown a photo array from which he identified Marin

as a participant in the home invasion. Defendant previously knew Marin only by nickname.

-3- -4- SSM No. 2

Defendant also waived immunity and testified before a grand jury regarding Sanchez’s

murder. During this testimony defendant again described his motive for the murder as the

home invasion and stated that Marin was one of the participants in that prior crime. The

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People v. Alexis Rodriguez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-alexis-rodriguez-ny-2019.