74 N.Y.2d 931 (1989)
A defendant’s claim that the trial court failed to explicitly advise him of potential second felony offender sentencing at the time of a guilty plea must be preserved by a motion to withdraw the plea or a motion to vacate the judgment of conviction; otherwise, the claim is unpreserved for appellate review unless it implicates fundamental fairness.
Summary
The New York Court of Appeals affirmed the Appellate Division’s order, holding that the defendant, Mayers, could not be relieved of his guilty plea because he failed to preserve his claim that the trial court did not explicitly advise him of the potential for second felony offender sentencing. The Court reasoned that because Mayers was informed of the potential sentence enhancement before entering his plea and received the bargained-for sentence, the claimed error was not a matter of fundamental fairness and was subject to standard preservation rules, which he did not follow by moving to withdraw his plea or vacate the judgment.
Facts
Defendant Mayers pleaded guilty. On appeal, Mayers claimed that the trial court committed a per se error by failing to explicitly advise him at the time of his guilty plea that he might be sentenced as a second felony offender. The record indicated that Mayers was informed of the potential sentence and enhancement before entering his plea and received the precise sentence bargained for.
Procedural History
The lower courts did not find error in the plea allocution. The case reached the Court of Appeals after Mayers appealed the lower court decisions upholding his conviction.
Issue(s)
Whether a defendant, who was informed of potential sentencing enhancements and received the bargained-for sentence, can challenge his guilty plea on appeal based on the trial court’s failure to explicitly advise him of second felony offender sentencing at the time of the plea, when he did not move to withdraw his plea or vacate the judgment of conviction.
Holding
No, because the claimed error, under these specific circumstances, is not a matter of fundamental fairness and is governed by standard preservation rules, which require the defendant to move to withdraw the plea or vacate the judgment to preserve the issue for appellate review.
Court’s Reasoning
The Court of Appeals emphasized the importance of preserving legal arguments at the trial level. It noted that CPL 220.60(3) and CPL 440.10 provide mechanisms for a defendant to challenge a guilty plea, either by moving to withdraw it before sentencing or by moving to vacate the judgment of conviction after sentencing. By failing to utilize these mechanisms, Mayers failed to give the trial court an opportunity to address the alleged error. The court distinguished the alleged error from claims implicating fundamental fairness. The Court highlighted that Mayers was informed of the potential sentence and enhancement before entering his plea and received the precise sentence for which he bargained. The court reasoned that under these circumstances, the alleged error did not rise to the level of fundamental unfairness requiring the court to overlook the lack of preservation. The court implicitly determined that the error did not affect the voluntariness or intelligence of the plea given that the defendant was aware of the potential consequences and received the agreed-upon sentence. The decision serves as a reminder that procedural rules and preservation requirements are strictly enforced unless the alleged error rises to the level of fundamental unfairness, thus undermining the integrity of the proceedings.