People v. Thomas, 53 N.Y.2d 338 (1981)
A defendant cannot preserve the right to appellate review of the legal sufficiency of conceded facts to support a conviction after entering a guilty plea, even with the consent of the prosecutor and approval of the trial court.
Summary
Defendant Thomas pleaded guilty to reckless endangerment and weapons charges, conditioning the plea on the right to appeal the sufficiency of the admitted facts and the constitutionality of a gun presumption statute. The Appellate Division refused to hear the appeal, holding that such a conditional plea was incompatible with sound administration of justice. The New York Court of Appeals affirmed, holding that allowing a defendant to plead guilty and simultaneously challenge the factual sufficiency of the evidence undermines the nature of a guilty plea as a conviction. The court emphasized the logical inconsistency of admitting guilt while attempting to maintain innocence on appeal.
Facts
Defendant was indicted for reckless endangerment, reckless driving, and weapons possession after a high-speed car chase in a residential area. Two concealed handguns were found in the car. Defendant admitted in written statements that during the 25-block chase, he reached 60 mph, ran five red lights, passed moving and parked cars, and drove through residential streets with some lights on in houses. He also admitted owning the two concealed weapons in the car and knowing their location.
Procedural History
The trial court approved an agreement allowing Defendant to plead guilty while preserving the right to appeal (1) whether the chase constituted “depraved indifference” for reckless endangerment and (2) the constitutionality of the gun presumption statute. The Appellate Division refused to consider the merits of these issues, vacating the plea. The Court of Appeals granted leave to appeal to determine the permissibility of such a conditional plea.
Issue(s)
Whether a defendant can condition a guilty plea on the right to appeal the legal sufficiency of conceded facts to support the conviction, with the consent of the prosecutor and approval of the trial court.
Holding
No, because permitting a defendant to plead guilty while simultaneously challenging the factual sufficiency of the evidence is logically inconsistent with the nature of a guilty plea as a conviction.
Court’s Reasoning
The Court of Appeals focused on the logical inconsistency of allowing a defendant to both admit guilt through a guilty plea and reserve the right to challenge the sufficiency of the facts supporting that guilt. The court reasoned that “[a] plea of guilty ‘is more than a confession which admits that the accused did various acts; it is itself a conviction [and] nothing [else] remains but to give judgment and determine punishment’ (Boykin v Alabama, 395 U. S. 238, 242).” Allowing such a conditional plea would undermine the solemnity of pleading guilty, turning it into a mere device for avoiding trial while maintaining a claim of innocence. While CPL 710.70(2) allows appeal of suppression motions after a guilty plea, the court distinguished that situation from challenging the underlying factual basis for the crime itself. The court explicitly declined to address the broader question of all possible issues that could be the subject of a conditional plea, limiting its holding to the specific facts of this case. The Court also noted that a defendant cannot unilaterally reserve a legal contention after a guilty plea; agreement of the prosecutor and approval of the court is required.