People v. Lopez

844 N.E.2d 1145, 6 N.Y.3d 248, 811 N.Y.S.2d 623
CourtNew York Court of Appeals
DecidedFebruary 16, 2006
StatusPublished
Cited by5,799 cases

This text of 844 N.E.2d 1145 (People v. Lopez) 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. Lopez, 844 N.E.2d 1145, 6 N.Y.3d 248, 811 N.Y.S.2d 623 (N.Y. 2006).

Opinions

OPINION OF THE COURT

Chief Judge Kaye.

Can a criminal defendant who has validly waived the right to appeal nonetheless ask the Appellate Division to exercise its interest-of-justice jurisdiction to reduce a sentence? We answer that question in the negative, though in so doing we underscore the critical nature of a court’s colloquy with a defendant explaining the right relinquished by an appeal waiver.

People v Lopez

Following arrest and indictment for possession and sale of a controlled substance in or near school grounds, defendant Lopez pleaded guilty to a reduced charge. In exchange for this plea, the court promised to impose a sentence of imprisonment of 21/2 to 5 years. At the time of the plea, defendant waived his right to appeal on the record, both verbally and in writing. Despite this waiver, on January 14, 2004, defendant, acting pro se, filed a timely notice of appeal, noting only that he would appeal the “conviction and/or sentence.” After appointment by the Appellate Division, appellate counsel argued that the Court should reduce defendant’s sentence in the interest of justice despite his waiver of the right to appeal.

The Appellate Division affirmed with respect to defendant’s sentence, holding that “defendant’s valid waiver of his right to appeal encompassed his excessive sentence claim and thus forecloses interest of justice review. In any event, were we to find that defendant did not validly waive his right to appeal, we would perceive no basis for reducing the sentence” (16 AD3d 258, 258 [1st Dept 2005] [citation omitted]). On defendant’s appeal of the excessive sentence issue, we now affirm the Appellate Division’s conclusion.

People v Billingslea

Defendant Billingslea, after suffering a psychotic episode, repeatedly stabbed both her best friend and her seven-year-old daughter, killing the child. Indicted for three counts of murder in the second degree and one count of attempted murder in the second degree—along with lesser crimes—defendant pleaded guilty to manslaughter in the first degree in satisfaction of all [254]*254charges and was sentenced to the agreed-upon prison term of 15 years.

During the plea allocution, the court asked defendant a series of questions concerning facts surrounding the homicide and whether she understood that by pleading guilty she was giving up the rights attendant to a criminal trial. After defendant responded “Yes,” the court then said to her, “And last, if you went to trial and were convicted, you would have what is known as the right of appeal. That means that a group of judges would review everything done in this case to make sure your rights have been protected, but when you plead guilty you waive your right of appeal.” Defendant again replied “Yes” when asked if she understood.

After defendant filed an appeal requesting a reduction of her sentence in the interest of justice, the Appellate Division affirmed her conviction and sentence stating, “The record demonstrates that the defendant knowingly, intelligently, and voluntarily waived her right to appeal, which included any challenge to her sentence, which was imposed pursuant to a negotiated plea agreement” (16 AD3d 516, 516 [2d Dept 2005]). Concluding that defendant’s waiver was not adequately informed, we now reverse and remit to the Appellate Division to consider defendant’s excessive sentence claim.

People v Nicholson

Defendant Nicholson was charged with attempted murder in the second degree as well as five related charges arising out of a 1999 knife fight with a rival gang member. In exchange for a promised prison sentence of eight years, defendant pleaded guilty. As part of his plea colloquy, and following an explanation of the trial rights forfeited by virtue of a guilty plea, the court said to defendant, “You also understand you’re giving up your right to appeal, that is, to take to a higher court than this one any of the legal issues connected with this case? You understand that?” Defendant answered “Yes.” One month later, prior to sentencing, the court reiterated, “[defendant is waiving his right to appeal in this matter.” Defendant raised no objection to that statement. Both the court and the court clerk noted in the record that defendant waived his right to appeal. Like defendant Billingslea, Nicholson did not execute a written appeal waiver.

On his appeal to the Appellate Division, defendant argued that the appeal waiver, as explained to him, was invalid and [255]*255that, even if the waiver was valid, the Appellate Division maintained its interest-of-justice authority to review what he believed was an excessive sentence. The Appellate Division concluded that the “valid waiver of [defendant’s] right to appeal encompassed his present claim that his agreed-upon sentence is excessive and forecloses interest of justice review of that claim. In any event, were we to find that review was not precluded, we would perceive no basis for reducing the sentence” (15 AD3d 237, 237-238 [1st Dept 2005] [citations omitted]). We agree that the waiver was valid and therefore affirm.

I

A defendant’s valid waiver of the right to appeal includes waiver of the right to invoke the Appellate Division’s interest-of-justice jurisdiction to reduce the sentence.

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Cite This Page — Counsel Stack

Bluebook (online)
844 N.E.2d 1145, 6 N.Y.3d 248, 811 N.Y.S.2d 623, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-lopez-ny-2006.