People v. Selikoff, 35 N.Y.2d 227 (1974)
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Judicial participation in plea bargaining, while potentially problematic, does not automatically constitute undue pressure that invalidates a guilty plea; the focus remains on whether the defendant’s plea was voluntary and knowing under the totality of the circumstances.
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Summary
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Selikoff appealed his conviction, arguing that the judge’s involvement in plea negotiations created undue pressure, rendering his guilty plea involuntary. The New York Court of Appeals affirmed the conviction, holding that while judicial involvement in plea bargaining is debatable, it doesn’t automatically equate to a deprivation of due process. The court emphasized that the key inquiry is whether the defendant experienced undue pressure, leading to an involuntary plea. Since Selikoff had twice entered into plea arrangements, even withdrawing one when the sentence wasn’t satisfactory, the court found no evidence of such undue pressure.
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Facts
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The defendant, Selikoff, entered into plea negotiations with the court, represented by his lawyer. Initially, a plea arrangement was made, but the court later rejected it after reviewing the presentence report, finding the promised sentence inappropriate. Subsequently, a second plea arrangement was negotiated, resulting in a more lenient sentence. The defendant then pleaded guilty and received the promised lesser sentence. Despite receiving the benefit of the plea bargain, Selikoff appealed, arguing that the judge’s involvement in the plea bargaining process inherently exerted undue pressure on him.
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Procedural History
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The case originated in a New York trial court where Selikoff pleaded guilty pursuant to a plea bargain. He appealed to the New York Court of Appeals, arguing his plea was coerced by the judge’s participation in the plea negotiations. The Court of Appeals affirmed the conviction, finding no undue pressure.
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Issue(s)
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Whether a judge’s participation in plea negotiations, resulting in a guilty plea and a subsequently fulfilled promise of a lesser sentence, constitutes undue pressure that invalidates the plea as involuntary.
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Holding
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No, because the defendant did not demonstrate that the judge’s participation created undue pressure that overcame his free will, considering he had entered into and benefitted from the plea agreements, even withdrawing from an earlier agreement when it proved unfavorable. The court emphasized that the “criminal system and atmosphere is necessarily ‘coercive,’” and only “undue pressure” warrants undoing a plea.
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Court’s Reasoning
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The court acknowledged the potential concerns regarding judicial involvement in plea bargaining, citing the American Bar Association’s standards on the matter. However, it declined to establish a per se rule against such involvement. The court emphasized that the central question remains whether the defendant’s plea was voluntary. It distinguished between the inherent