People v. Lynn, 28 N.Y.2d 196 (1971)
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A defendant who pleads guilty is not automatically entitled to a hearing to determine if they were informed of their right to appeal unless they allege a genuine appealable issue existed at the time of the plea.
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Summary
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Lynn and Saunders separately appealed the denial of their coram nobis petitions, arguing their attorneys failed to advise them of their right to appeal their convictions, which were based on guilty pleas. The New York Court of Appeals distinguished between convictions resulting from trials and guilty pleas. The Court held that while defendants convicted after trial must be informed of their right to appeal, a different standard applies to guilty pleas. A defendant pleading guilty must demonstrate a genuine appealable issue existed at the time of the plea to warrant a hearing on whether they were properly advised of their appellate rights. Because neither petitioner alleged such an issue, the Court affirmed the denial of their petitions.
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Facts
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Peter Lynn pleaded guilty to manslaughter in the first degree during his murder trial in 1951, and was sentenced as a second felony offender. He later claimed his attorneys never informed him of his right to appeal, a claim he made only after the decisions in People v. Montgomery and People v. Callaway. Milton Saunders pleaded guilty to robbery in the second degree in 1962. He also later claimed his counsel failed to inform him of his right to appeal. Neither Lynn nor Saunders directly appealed their convictions.r
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Procedural History
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Both Lynn and Saunders filed petitions for writs of error coram nobis, alleging ineffective assistance of counsel due to the failure to advise them of their right to appeal. The Supreme Court denied both petitions without evidentiary hearings, distinguishing their cases from People v. Montgomery, which concerned a conviction after trial. The Appellate Division affirmed the denial in both cases, requiring petitioners to allege not only that they were not informed of their right to appeal, but also that they were unaware of the right and would have appealed had they known. Lynn and Saunders then appealed to the New York Court of Appeals.r
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Issue(s)
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Whether assigned counsel must advise a defendant of their right to appeal after a plea of guilty, pursuant to the rule established in People v. Montgomery.r
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Holding
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No, because a different standard applies to guilty pleas; a defendant pleading guilty must demonstrate a genuine appealable issue existed at the time of the plea to warrant a hearing on whether they were properly advised of their appellate rights.r
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Court’s Reasoning
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The Court distinguished People v. Montgomery, which mandated advising defendants of their right to appeal after a trial, from cases involving guilty pleas. The Court reasoned that a guilty plea