People v. Petgen, 69 N.Y.2d 687 (1986)
A guilty plea generally results in the forfeiture of the right to appellate review of nonjurisdictional defects in the proceedings, including the denial of a suppression motion, unless a final order denying the suppression motion was obtained before the plea.
Summary
The New York Court of Appeals affirmed the Appellate Division’s order, holding that the defendant’s guilty plea forfeited his right to appellate review of the denial of his suppression motion because he pleaded guilty before obtaining a final order on the motion. The court reasoned that CPL 710.70(2), which provides an exception for reviewing suppression orders after a guilty plea, only applies if a final order denying the motion was issued before the plea. The court also noted that the defendant’s subjective belief that his plea would not result in forfeiture was irrelevant. By pleading guilty before the suppression hearing, the defendant also precluded the creation of a factual record necessary for appellate review.
Facts
The defendant was arrested and charged with a crime. He moved to suppress evidence, arguing that it was obtained illegally. However, before the court ruled on his suppression motion, the defendant entered a guilty plea.
Procedural History
The trial court accepted the defendant’s guilty plea. The Appellate Division affirmed the conviction. The case then went to the New York Court of Appeals.
Issue(s)
1. Whether a defendant who pleads guilty before obtaining a final order denying a motion to suppress evidence forfeits the right to appellate review of the suppression ruling under CPL 710.70(2)?
Holding
1. Yes, because CPL 710.70(2) provides a limited exception allowing review of suppression orders after a guilty plea only when a final order denying the motion was obtained before the plea. Furthermore, pleading guilty before the hearing precludes the creation of a record for appellate review.
Court’s Reasoning
The Court of Appeals stated that “[a] guilty plea generally results in a forfeiture of the right to appellate review of any nonjurisdictional defects in the proceedings.” The court emphasized that CPL 710.70(2) carves out a limited exception allowing review of a suppression order after a guilty plea, but only if the order was obtained *before* the plea. The court rejected the argument that the defendant’s subjective belief about the plea’s consequences could override the law. The Court reasoned that allowing such subjective beliefs to dictate the outcome would permit “evasion of what otherwise would be the consequences of the plea.” The Court further noted that the defendant’s guilty plea, entered before the suppression hearing, prevented the creation of a factual record necessary for appellate review, relying on People v. Charleston. In essence, the Court emphasized the importance of adhering to established procedural rules and the consequences of failing to do so.