People v. Wilson, 13 N.Y.2d 277 (1963)
New York courts will not provide a forum (through coram nobis or habeas corpus) to challenge the validity of a prior out-of-state conviction used to enhance sentencing in New York, unless the rendering court lacked jurisdiction.
Summary
Wilson, convicted in New York as a second felony offender based on a prior Florida conviction, sought coram nobis relief in New York, arguing his Florida conviction was unconstitutional because he lacked counsel. The New York Court of Appeals affirmed the denial of relief, reiterating that New York courts will not entertain collateral attacks on out-of-state convictions used for sentencing enhancement unless the rendering court lacked jurisdiction. The court reasoned that while the defendant may have a federal remedy, New York is not obligated to provide a forum to challenge the foreign judgment’s validity.
Facts
In 1948, Alfred Wilson was convicted of attempted murder in New York and sentenced as a second felony offender. The predicate felony was a 1931 Florida murder conviction. At sentencing, Wilson admitted the truth of the information regarding his prior felony. In 1962, Wilson filed a coram nobis petition in New York, arguing his Florida conviction was invalid because he was not represented by counsel or advised of his right to counsel in Florida. He submitted affidavits from Florida court officials and an attorney supporting his claim.
Procedural History
Wilson sought a writ of error coram nobis in the New York court where he was sentenced as a second felony offender, challenging the validity of the Florida conviction underlying his enhanced sentence. The lower court denied the petition. The New York Court of Appeals affirmed the lower court’s decision, upholding the denial of coram nobis relief.
Issue(s)
Whether New York State must provide a forum (through coram nobis or habeas corpus) for a defendant to challenge the constitutional validity of an out-of-state conviction used as a predicate for enhanced sentencing in New York.
Holding
No, because New York State is under no duty to provide a forum for attacking a foreign judgment, and New York can rely on the face value of the Florida conviction for sentencing purposes.
Court’s Reasoning
The Court of Appeals relied on its prior holding in People v. McCullough, which established that New York courts will not grant a hearing on the validity of an out-of-state conviction used for multiple offender sentencing unless the rendering court lacked jurisdiction. The court reasoned that coram nobis must be brought in the court that entered the judgment under attack, and habeas corpus is only available when the sentencing court lacked jurisdiction. The court acknowledged the Second Circuit’s decision in United States ex rel. La Near v. La Vallee, which held that a defendant in this situation may seek federal habeas corpus relief without exhausting out-of-state remedies, but stated this did not require New York to revise its own rules regarding collateral attacks on foreign judgments. The court expressed concern about the practical difficulties and burdens that would arise if New York courts were required to examine the validity of criminal judgments from other jurisdictions. The court noted that subsequent offender statutes are constitutional and do not require inquiry into the circumstances of the prior adjudication. As stated in the ruling, “the courts of this State have no alternative but to treat the conviction as an effective predicate for multiple offender punishment under section 1941 or section 1942 of the Penal Law.”