Matter of Timothy M. v. Erie County Court, 88 N.Y.2d 988 (1996)
Trial courts possess the inherent authority to correct their own errors in criminal cases before sentencing.
Summary
This case addresses the scope of a trial court’s power to correct its own errors before sentencing. The defendant, initially indicted on felony and misdemeanor weapon possession charges, pleaded guilty to the misdemeanor after the trial court indicated the felony charge was dismissed. However, the court later issued a written decision denying the motion to dismiss the felony charge. The court then offered the defendant an opportunity to withdraw his plea, which he refused. The Court of Appeals held that the trial court acted within its inherent authority to correct its own mistakes before sentencing, reversing the Appellate Division’s order compelling the court to impose the originally agreed-upon sentence.
Facts
Timothy M. was indicted on felony and misdemeanor counts of criminal possession of a weapon. He moved to dismiss the indictment. The Trial Justice announced from the Bench that the felony charge was dismissed, though no formal decision was rendered. Based on this, the defendant pleaded guilty to the misdemeanor charge, with an agreed-upon sentence of three years’ probation. The Trial Justice subsequently filed a written decision denying the motion to dismiss the indictment, thus reinstating the felony charge. On the sentencing date, the court advised the parties that the felony count was reinstated and offered the defendant the opportunity to withdraw his guilty plea, which he refused.
Procedural History
The defendant initiated a CPLR article 78 prohibition proceeding to prevent the Trial Justice from vacating the guilty plea and to compel the court to impose the originally agreed-upon sentence. The Appellate Division granted the petition, ordering the case remanded for sentencing according to the agreement. The Court of Appeals reversed the Appellate Division’s judgment and dismissed the petition.
Issue(s)
Whether a trial court, before sentencing, has the authority to correct its own prior mistake of dismissing a felony charge when it later determines the dismissal was erroneous, and offer the defendant the opportunity to withdraw a guilty plea to a related misdemeanor charge.
Holding
Yes, because trial courts in criminal cases possess the inherent authority to correct their own mistakes before sentencing.
Court’s Reasoning
The Court of Appeals based its decision on the principle that trial courts have the inherent authority to correct their own errors before sentencing. The court cited People v. Bartley, 47 N.Y.2d 965 (1979), and People v. Minaya, 54 N.Y.2d 360 (1981), to support this proposition. The Court reasoned that the Trial Justice’s actions fell within this established principle, especially given the unusual circumstances of the case, in which the court initially indicated the felony charge was dismissed but later formally denied the motion to dismiss. The Court distinguished this case from situations where the court’s power to correct errors is more limited, such as in Matter of Kisloff v. Covington, 73 N.Y.2d 445 (1989), and Matter of Campbell v. Pesce, 60 N.Y.2d 165 (1983). The Court held that, as a matter of law for prohibition purposes, the Trial Justice did not improperly exercise his authority, stating that, “In a standard application of this principle to the unusual developments here, the Trial Justice cannot be said, as a matter of law for prohibition purposes, to have improperly exercised such authority.”