Matter of Weinstein v. Haft, 66 N.Y.2d 625 (1985)

A court does not lose jurisdiction to sentence a defendant, even after a significant delay following a guilty plea, when the delay is primarily at the defendant’s request and the court has a reasonable basis for further postponement.

Summary

Weinstein pleaded guilty but sentencing was delayed for over three years at her request. She then moved to dismiss the charges, arguing the court lost jurisdiction due to the delay. The Court of Appeals held that the delay, primarily caused by Weinstein, was not so “extremely long and unreasonable” as to divest the court of its sentencing power. The court also found that denial of mandamus relief was proper because the further delay to obtain medical reports was not an abuse of discretion given the possibility of improved health affecting sentencing.

Facts

The key facts are:

1. Weinstein pleaded guilty to an unspecified crime.
2. Sentencing was delayed for over three years at Weinstein’s request.
3. Weinstein moved to dismiss the charges, claiming the court lost jurisdiction due to the delay.
4. The trial court adjourned the motion for a further year, pending receipt of a medical report on Weinstein’s treatment.

Procedural History

The procedural history is as follows:

1. Weinstein sought relief by way of prohibition and mandamus in the lower courts.
2. The Appellate Division’s judgment was appealed to the New York Court of Appeals.
3. The Court of Appeals affirmed the Appellate Division’s judgment.

Issue(s)

1. Whether allowing over three years to elapse from a guilty plea without sentencing, when the delay is at the defendant’s behest, divests the court of its jurisdiction to sentence the defendant.
2. Whether the denial of mandamus relief was proper where sentencing was delayed at the petitioner’s request and the trial judge postponed disposition pending receipt of a further medical report.

Holding

1. No, because the first three years of delay were at the petitioner’s request and the additional time does not constitute such an “extremely long and unreasonable” delay as to divest the court of its power to sentence.
2. Yes, because sentencing was delayed at the petitioner’s request, and in view of medical testimony that further treatment might improve petitioner’s physical condition, it was not an abuse of discretion for the Trial Judge to postpone disposition of the motion pending receipt of a further medical report.

Court’s Reasoning

The court reasoned that:

1. The delay, being primarily at Weinstein’s request, distinguished the case from those where the court’s inaction led to a loss of jurisdiction. The Court cited People ex rel. Harty v Fay, 10 NY2d 374, 379, emphasizing that only an “extremely long and unreasonable” delay could divest the court of its power to sentence.
2. The denial of mandamus was appropriate because sentencing delays were at Weinstein’s request, and the trial court had a valid reason (medical reports) for further postponement. The court acknowledged mandamus can compel a determination of a motion and proceeding with sentencing, citing Matter of Briggs v Lauman, 21 AD2d 734, Matter of Legal Aid Soc. v Scheinman, 73 AD2d 411, 413, and Matter of Hogan v Bohan, 305 NY 110.
3. The court considered the medical testimony suggesting further treatment could improve Weinstein’s condition. This potential improvement provided a reasonable basis for the trial judge’s decision to postpone disposition pending the receipt of further medical information. This highlights the trial court’s discretion in sentencing matters.