People v. Flowers, 41 N.Y.2d 840 (1977)
A defendant should be allowed to withdraw a guilty plea if it was induced by unfulfilled promises made by law enforcement, especially when the defendant was without counsel at the time of the plea.
Summary
Flowers pleaded guilty to disorderly conduct and resisting arrest after a police officer allegedly promised he would be released on his own recognizance if he did so. Prior to sentencing, and after obtaining counsel, Flowers moved to withdraw his plea, asserting his innocence and the unfulfilled promise. The prosecutor denied the promise based on conversations with unnamed officers. The trial court denied the motion without a hearing, and the appellate court affirmed. The New York Court of Appeals reversed, holding that the trial court erred in denying the motion to withdraw the plea without a hearing, given the defendant’s assertion of a promise that was not effectively refuted with supporting proof from the prosecution.
Facts
Flowers was arrested for disorderly conduct and resisting arrest. He was arraigned the next morning without counsel. He pleaded guilty to both charges after being advised of his rights. Before the plea, a police officer allegedly told Flowers that if he pleaded guilty, he would be released on his own recognizance to return to work.
Procedural History
The Canandaigua City Court accepted Flowers’s guilty pleas and set a date for sentencing. After consulting an attorney (who wasn’t retained initially), a letter was sent requesting assigned counsel and asserting Flowers’s innocence. The court assigned counsel. Assigned counsel moved to withdraw the guilty plea. The City Court denied the motion without a hearing. Ontario County Court affirmed the convictions. The New York Court of Appeals reversed the order of the County Court, vacated the judgment of conviction, and remitted the case for further proceedings.
Issue(s)
Whether the trial court erred in denying the defendant’s motion to withdraw his guilty plea without a hearing, given the defendant’s claim that the plea was induced by a police officer’s unfulfilled promise of release, and the prosecutor’s denial based on conversations with unnamed officers.
Holding
Yes, because the defendant’s assertion of a promise that induced his plea, made without the benefit of counsel, was not effectively refuted by the prosecutor’s conclusory denial without supporting proof, thus warranting a hearing on the motion to withdraw the plea.
Court’s Reasoning
The Court of Appeals reasoned that the defendant’s claim of a promise by a police officer, which induced his guilty plea, was a significant factor that required a more thorough examination by the trial court. The court emphasized that the prosecutor’s denial, based solely on