People v. Rivera, 71 N.Y.2d 705 (1988)
A plea of guilty generally precludes appellate review of nonjurisdictional defects in the proceedings, except where the indictment fails to effectively charge the defendant with a particular crime.
Summary
The New York Court of Appeals held that a guilty plea generally precludes appellate review of nonjurisdictional defects in criminal proceedings. The defendants pleaded guilty to attempted promoting prison contraband after being indicted for promoting prison contraband. They later challenged their indictments, arguing defects related to the definition and filing of regulations concerning “dangerous contraband”. The Court of Appeals affirmed the lower court’s order, holding that because the indictments cited the relevant statute and alleged acts constituting the crime, any defect was nonjurisdictional and waived by the guilty pleas. The Court emphasized that a guilty plea marks the end of a criminal case, not a gateway to further litigation of nonjurisdictional issues.
Facts
Each defendant was indicted for promoting prison contraband in the first degree, in violation of Penal Law § 205.25(2). Each defendant pleaded guilty to the attempted offense in full satisfaction of the indictment and received a negotiated sentence. The contraband in question was a sharpened metal shank or rod. The defendants subsequently challenged the validity of their indictments, arguing that the definition of “dangerous contraband” was flawed because the relevant rule or regulation was not properly filed.
Procedural History
The defendants appealed their convictions, arguing that the indictments were jurisdictionally defective. The Appellate Division affirmed the convictions. The New York Court of Appeals granted leave to appeal and affirmed the Appellate Division’s order.
Issue(s)
Whether a guilty plea precludes appellate review of a claim that the indictment was defective because the definition of “dangerous contraband” relied upon an improperly filed rule or regulation?
Holding
No, because the defect alleged was nonjurisdictional and therefore waived by the guilty plea. The indictment cited the relevant statute and alleged acts that would constitute the statutory elements of the crime.
Court’s Reasoning
The Court of Appeals reasoned that a guilty plea generally precludes appellate review of nonjurisdictional defects. A defect is only considered jurisdictional if the indictment does not effectively charge the defendant with the commission of a particular crime. Here, the indictments cited Penal Law § 205.25(2) and alleged acts that, if proven, would establish the statutory elements of the crime. The court cited People v. Cohen, stating that “[t]he incorporation [in an indictment] by specific reference to the statute [defining the crime charged] operates without more to constitute allegations of all the elements of the crime required by explicit provision of the statute itself or by judicial gloss overlaid thereon”. The court distinguished this case from Matter of Jones v. Smith, where the failure to file a regulation nullified the basis of the proceeding. Here, the criminal action was based on a statute incorporating the substance of the rule or regulation, not the regulation itself. Furthermore, the Court noted that the defendants did not claim lack of notice that possessing a sharpened metal shank or rod was prohibited. Therefore, the defendants’ challenges were nonjurisdictional and precluded by their guilty pleas. The Court underscored the principle that a guilty plea represents a compromise, marking the end of a criminal case, not an invitation for further litigation of issues that do not fundamentally challenge the court’s jurisdiction.