92 N.Y.2d 511 (1998)
A withdrawn guilty plea to a traffic violation, vacated on grounds other than due process violations, is admissible as evidence in a subsequent civil action related to the same incident, subject to the defendant’s opportunity to explain the circumstances of the plea.
Summary
This case addresses whether a withdrawn guilty plea to a traffic offense can be used as evidence in a later civil trial. The plaintiff sued the defendant for injuries sustained in a car accident. The defendant had previously pleaded guilty to a traffic violation related to the accident, but later withdrew the plea. At the civil trial, the plaintiff attempted to introduce the withdrawn plea to impeach the defendant’s testimony. The trial court disallowed it, but the New York Court of Appeals reversed, holding the plea admissible, as its vacatur wasn’t based on due process violations. The court emphasized the distinction between criminal and civil contexts and allowed the defendant an opportunity to explain the circumstances of the plea to the jury.
Facts
On July 31, 1992, Mary E. Cohens was injured in a car accident with a vehicle driven by the defendant, Hess. The accident occurred at an intersection controlled by a stop sign facing Hess. Following the accident, Hess was cited for failure to yield the right of way. On August 13, 1992, Hess pleaded guilty to failure to obey a traffic control device and paid a $75 fine. Three years later, after the civil suit commenced, Hess moved to vacate his guilty plea, claiming he lacked legal counsel when he entered it. The court allowed Hess to withdraw his plea and plead guilty to a non-moving violation.
Procedural History
The plaintiff, Mary E. Cohens, sued the defendant, Hess, for personal injuries. At trial, the court prohibited the plaintiff from using Hess’s withdrawn guilty plea for impeachment. The jury returned a verdict for the plaintiff but found her 60% at fault. The plaintiff’s motion to set aside the verdict was denied. The Appellate Division affirmed. The New York Court of Appeals reversed, finding the plea admissible.
Issue(s)
Whether a guilty plea to a traffic offense, which has been withdrawn by leave of the court, is admissible as evidence in a subsequent civil action for damages arising from the same incident, when the withdrawal was not based on a violation of due process?
Holding
Yes, because the vacatur of the defendant’s plea was not based upon any violation of due process grounds, in the circumstances presented, the plaintiff’s intended use of the plea is proper. However, the defendant must be permitted a full and fair opportunity to offer the jury his reasons for the withdrawn plea.
Court’s Reasoning
The Court of Appeals began by stating that all facts having rational probative value are admissible unless a specific rule forbids it. The Court distinguished its prior holding in People v. Spitaleri, 9 N.Y.2d 168, which held that a withdrawn guilty plea could not be used against a criminal defendant as an admission of guilt, emphasizing that Spitaleri was based on fundamental fairness grounds specific to criminal proceedings. The Court noted that allowing the use of a withdrawn plea in a criminal trial could effectively force the defendant to testify. Citing Ando v. Woodberry, 8 N.Y.2d 165, the Court reiterated that guilty pleas to traffic violations are generally admissible in subsequent civil actions as proof of negligence. The Court emphasized that the City Court’s decision to allow the defendant to withdraw his plea was discretionary and not based on any finding of coercion or misrepresentation. The Court reasoned that the defendant should be allowed to explain his reasons for the withdrawn plea to the jury, allowing the jury to determine how much weight to give the evidence. The court stated, “In our view, since the vacatur of defendant’s plea was not based upon any violation of due process grounds, in the circumstances presented, plaintiffs intended use of the plea is proper, while defendant’s attempted use of Spitaleri is misplaced. The fundamental differences in the considerations at work in criminal and civil trials compel the conclusion that Spitaleri is inapplicable here.”