People v. Steadman, 82 N.Y.2d 1 (1993)
A defendant’s guilty plea generally waives the right to challenge an indictment based on an ex post facto argument concerning a change in evidentiary rules, as such a challenge relates to the quantum of proof necessary to establish the factual elements of the crime.
Summary
Defendant Steadman pleaded guilty to two counts of endangering the welfare of a child. He then appealed, arguing that the elimination of a corroboration requirement for certain sex offenses after the commission of the crimes violated the constitutional prohibition against ex post facto laws. Steadman claimed that eliminating the corroboration rule lessened the prosecution’s burden of proof. The New York Court of Appeals affirmed the Appellate Division’s decision, holding that a guilty plea waives such an ex post facto challenge rooted in an evidentiary rule change. The court reasoned that the change related to the quantum of proof, not the fundamental definition of the crime itself.
Facts
The defendant was indicted on multiple counts, including charges related to endangering the welfare of a child. The crimes were committed prior to an amendment to Penal Law § 130.16, which eliminated the corroboration requirement for certain sex offenses. The defendant moved to dismiss the indictment, arguing that the elimination of the corroboration requirement violated the ex post facto clause of the Constitution because it applied to crimes he allegedly committed before the change in law.
Procedural History
The County Court denied the defendant’s motion to dismiss the indictment. Subsequently, the defendant pleaded guilty to two counts of endangering the welfare of a child. The Appellate Division affirmed the lower court’s decision. The New York Court of Appeals granted leave to appeal and affirmed the Appellate Division’s order.
Issue(s)
Whether a defendant, by pleading guilty, waives the right to challenge an indictment on the grounds that the elimination of a corroboration requirement constitutes an ex post facto violation because it lessens the People’s burden of proof.
Holding
Yes, because an ex post facto argument rooted in an evidentiary rule change, like the elimination of a corroboration requirement, relates essentially to the quantum of proof required to satisfy factual elements of a crime, and this is waived by a guilty plea.
Court’s Reasoning
The Court of Appeals reasoned that the defendant’s ex post facto claim, based on the change in the corroboration rule, concerned the amount of evidence needed to prove the elements of the crime, not the definition of the crime itself. The court cited prior cases, including People v. Taylor, 65 NY2d 1, People v. Pelchat, 62 NY2d 97, 108, and People v. Thomas, 53 NY2d 338, 342, 2, to support its holding that challenges to the sufficiency of evidence before a grand jury are generally waived by a guilty plea. The court stated, “Even if we assume that the asserted claim is error — and we do not decide that issue on the merits in this case — the Appellate Division correctly held that this ex post facto argument, rooted in an evidentiary rule change, is lost by a plea of guilty because it relates essentially to the quantum of proof to satisfy factual elements of a crime before the Grand Jury.” The court emphasized that a guilty plea represents an admission of factual guilt and a waiver of certain constitutional rights related to trial. Because the ex post facto argument concerned an evidentiary matter, it was deemed waived by the plea. The court explicitly did not decide on the merits of whether the elimination of the corroboration requirement was actually an ex post facto violation in this case, focusing instead on the waiver issue.