People v. Selikoff, 35 N.Y.2d 227 (1974)
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A defendant is not entitled to withdraw a guilty plea when the sentencing court adheres to the promises made during the plea agreement, even if the defendant subjectively misinterpreted the terms.
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Summary
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The New York Court of Appeals addressed whether a defendant should be allowed to withdraw a guilty plea after the sentencing court fulfilled its promises made during the plea bargain. Selikoff pleaded guilty to a reduced charge, and the court promised specific sentencing options based on the Probation Department’s recommendation, including the possibility of commitment to the Narcotic Addiction Control Commission or a prison sentence with a maximum of five years. After the Probation Department recommended a prison sentence due to Selikoff’s extensive prior convictions, the court sentenced him accordingly. The Court of Appeals held that because the sentencing court kept its promises, Selikoff was not entitled to withdraw his plea based on a subjective misinterpretation of the agreement. Compliance with plea agreements is assessed objectively, not based on the defendant’s personal understanding.
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Facts
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The defendant, Selikoff, entered a guilty plea to a reduced charge.r
During the plea proceedings, the court made specific promises regarding sentencing:r
– If the Probation Department recommended it, the court would sentence Selikoff to the Narcotic Addiction Control Commission for five years.r
– If the Probation Department recommended a prison sentence, the court would impose a maximum term of five years.r
– If, after reviewing the probation report, the court could not honor the promises, Selikoff would be allowed to withdraw his guilty plea.r
The Probation Department recommended a prison sentence due to Selikoff’s numerous prior convictions.r
The court sentenced Selikoff to an indeterminate prison term with a maximum of five years, consistent with the Probation Department’s recommendation and the court’s prior assurances.r
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Procedural History
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The defendant was sentenced after pleading guilty.r
The defendant moved to withdraw the guilty plea, which was denied by the sentencing court.r
The defendant subsequently filed a motion in the nature of coram nobis to vacate the judgment, which was also denied.r
The Appellate Division affirmed the lower court’s decisions.r
The case was then appealed to the New York Court of Appeals.r
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Issue(s)
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Whether a defendant is entitled to withdraw a guilty plea when the sentencing court fulfills the promises made during the plea agreement, but the defendant claims to have misinterpreted the agreement.r
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Holding
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No, because compliance with a plea bargain is tested against an objective reading of the bargain, not against a defendant’s subjective interpretation. Where a sentencing court keeps the promises it made at the time it accepted a plea of guilty, a defendant should not be permitted to withdraw his plea on the sole ground that he misinterpreted the agreement.r
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Court’s Reasoning
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The court emphasized that the sentencing court kept its promises made during the plea agreement.r
The court reasoned that allowing a defendant to withdraw a plea based solely on a subjective misinterpretation would undermine the integrity of the plea bargaining process.r
The court adopted an objective standard for evaluating compliance with plea agreements, stating that compliance is to be tested against an objective reading of the bargain, and not against a defendant’s subjective interpretation thereof.r
The court highlighted the potential for abuse if subjective interpretations were allowed, noting that it