People v. La Ruffa, 37 N.Y.2d 58 (1975)
A defendant’s knowing and intelligent guilty plea, made with advice of counsel, constitutes a waiver of their right against double jeopardy, even if subsequent legal developments expand that right retroactively.
Summary
La Ruffa was initially convicted of second-degree murder, but that conviction was overturned. He was retried for first-degree murder. During the second trial, La Ruffa, with counsel, pleaded guilty to second-degree murder. Years later, he sought to vacate the conviction, arguing double jeopardy because he was retried on the original first-degree murder charge after initially being convicted of a lesser charge in the first trial. The court held that La Ruffa’s guilty plea waived his double jeopardy claim, even though the legal understanding of double jeopardy had evolved since his plea. The court emphasized the importance of finality in convictions resulting from valid guilty pleas.
Facts
La Ruffa was indicted for first-degree murder in 1952 and convicted of second-degree murder. His conviction was overturned on appeal, and a new trial was ordered. In 1957, during his retrial on the original first-degree murder indictment, La Ruffa, with advice of counsel, withdrew his not guilty plea and pleaded guilty to second-degree murder. He later attempted to withdraw his plea, claiming he was in a “bad state of mind,” but the motion was denied. No appeal was taken at that time.
Procedural History
In 1970, a coram nobis application led to the 1957 judgment being vacated due to a deprivation of the right to appeal. La Ruffa was resentenced nunc pro tunc as of April 4, 1957. On appeal, he argued double jeopardy. The Appellate Division affirmed the conviction, holding that the guilty plea waived the double jeopardy claim. This appeal followed.
Issue(s)
Whether a defendant’s knowing and intelligent guilty plea to a lesser charge constitutes a waiver of a double jeopardy claim, precluding him from later asserting that claim based on subsequent retroactive expansions of double jeopardy protections.
Holding
Yes, because a guilty plea, entered knowingly and intelligently with advice of counsel, constitutes a waiver of the right not to be twice subjected to the risk of punishment for the same offense, even if the constitutional law regarding double jeopardy evolves retroactively after the plea.
Court’s Reasoning
The court reasoned that while the Fifth Amendment’s double jeopardy clause applies to the states via the Fourteenth Amendment, and prevents retrying a defendant for a crime they were implicitly acquitted of by a conviction on a lesser offense, these developments in double jeopardy law occurred *after* La Ruffa’s guilty plea. The court stated, “When a defendant admits his guilt and consents to the entry of judgment against him, he does so under the law then existing.” It is not contended that the plea was involuntary or unintelligent. The court emphasized the importance of finality in convictions. Quoting Brady v. United States, 397 U. S. 742, 757; McMann v. Richardson, 397 U. S. 759, 773-774 the State has a legitimate interest in maintaining the finality of convictions attributable to guilty pleas valid under constitutional standards existent at the time. Because there was no claim of duress, coercion or lack of awareness, the negotiated plea, made with the advice of competent counsel in light of the then existing law, should not be set aside merely because of a subsequent change in double jeopardy law.