People v. Esajerre, 35 N.Y.2d 463 (1974)
A defendant may waive their right to a judicial determination on a suppression motion as part of a plea agreement, provided the waiver is knowing, intelligent, and voluntary, and the plea agreement itself is not the result of coercion or duress.
Summary
Esajerre, a Chilean national, was arrested for drug possession. After indictment, he moved to suppress the evidence. During the suppression hearing, plea negotiations occurred. The prosecution offered a reduced charge if Esajerre withdrew his suppression motion. Esajerre, concerned about parole due to his nationality, withdrew the motion and pled guilty. On appeal, he argued the waiver was invalid. The New York Court of Appeals affirmed the conviction, holding that a defendant can waive the right to a suppression hearing determination as part of a plea bargain if the waiver is knowing and voluntary, and the circumstances do not amount to coercion.
Facts
Responding to a burglary call, police found Esajerre in a hallway with a paper bag. A search of the bag revealed cocaine. Esajerre was given Miranda warnings in Spanish and admitted ownership of the drugs. He later turned over additional cocaine. He was indicted, and a motion to suppress the seized evidence was filed.
Procedural History
After the suppression hearing, Esajerre requested an adjournment to prepare a summation. Plea negotiations ensued, and the prosecution offered a reduced charge in exchange for withdrawing the suppression motion. Esajerre withdrew the motion and pled guilty. He appealed, arguing his waiver was invalid as a matter of law. The appellate division affirmed, and the case was appealed to the New York Court of Appeals.
Issue(s)
Whether a defendant’s waiver of a judicial determination on a suppression motion, as a condition of a plea bargain, is invalid as a matter of law.
Holding
No, because a defendant can knowingly and voluntarily waive the right to a judicial determination on a suppression motion as part of a plea agreement, provided that the plea agreement is not the result of coercion or duress.
Court’s Reasoning
The Court of Appeals reasoned that a defendant can waive certain rights, including the right to a jury trial and the right to challenge the admissibility of evidence. The court distinguished this case from People v. White, 32 N.Y.2d 393 (1973) and People v. Blakley, 34 N.Y.2d 311 (1974), where waivers of the right to a speedy trial were deemed invalid due to coercion and unreasonable delay. Here, the court found no evidence of coercion. Esajerre had sufficient time to discuss the waiver with his lawyer and understood the consequences of his guilty plea. The court emphasized the extensive discussions between Esajerre, his counsel, and the prosecution, stating that this “afforded defendant sufficient opportunity to weigh ‘the relative merits of the plea offered against the hazards of a trial’ and assured that the plea was voluntary.” The court noted that offering a reduced plea is a matter of grace, and reasonable conditions, like withdrawing the suppression motion, can be attached. Esajerre’s concern about parole was addressed by the prosecution’s assurance. Since Esajerre could waive his right to attack the search, he could also waive the right to a final determination on his claim. “Since the defendant could waive his right to attack the search as unreasonable, he could waive the right to an ultimate determination of his claim.” The court concluded the waiver was a knowing and intelligent decision.