People v. Hansen, 95 N.Y.2d 227 (2000)
A guilty plea generally forfeits the right to appellate review of claims relating to rights deprivations occurring before the plea, except for jurisdictional defects or constitutional rights impacting the process’s integrity.
Summary
Hansen pleaded guilty to attempted burglary. He then sought to challenge his indictment, arguing that the Grand Jury proceedings were impaired by the prosecutor’s introduction of inadmissible hearsay (a news report). The trial court rejected this argument, and the Appellate Division affirmed, holding that the guilty plea waived the right to challenge the Grand Jury proceeding. The New York Court of Appeals affirmed, holding that the guilty plea forfeited the right to challenge the Grand Jury proceeding because the defect was evidentiary, not jurisdictional or constitutional.
Facts
Harold Stickney testified before the Grand Jury that he awoke to noises outside his home, saw Hansen on his porch with a shovel trying to break in, and confronted him with a gun. Deputy Stark testified that he apprehended Hansen, who claimed he was there to shovel snow. Hansen testified that he was under the influence of medication and hallucinating. The prosecutor then played a portion of a news report where a reporter stated that Hansen was charged with attempted burglary. The prosecutor told the grand jurors to only consider Hansen’s statement on the tape. Hansen was indicted for burglary and related charges.
Procedural History
Hansen moved to dismiss the indictment, arguing the Grand Jury proceeding was defective due to the hearsay in the news report. The motion court denied the motion. Hansen pleaded guilty to attempted first-degree burglary. The Appellate Division affirmed, holding the plea waived the challenge to the Grand Jury proceeding. Hansen appealed to the New York Court of Appeals.
Issue(s)
Whether a defendant who pleads guilty forfeits the right to argue on appeal that the Grand Jury proceedings were impaired by the prosecutor’s introduction of inadmissible hearsay evidence.
Holding
No, because the defect was not jurisdictional or a constitutional violation that impacted the integrity of the process. The Court of Appeals held that the defendant’s guilty plea forfeited his right to challenge the Grand Jury proceeding on the basis of the inadmissible hearsay.
Court’s Reasoning
The Court of Appeals reasoned that a guilty plea generally marks the end of a criminal case. A guilty plea encompasses a waiver of specific trial rights and forfeits the right to revive certain pre-plea claims. However, issues relating to jurisdictional matters or constitutional rights that go to the heart of the process survive a guilty plea. The court distinguished between defects implicating the integrity of the process, which may survive a guilty plea, and less fundamental flaws, such as evidentiary or technical matters, which do not. Here, the Court found that the introduction of the videotaped remarks was an evidentiary error, not a jurisdictional or constitutional one. “Flaws of an evidentiary or technical nature are thus forfeited by a guilty plea.” The court noted that a valid and sufficient accusatory instrument existed, enabling the court to acquire jurisdiction. The court distinguished this case from People v. Pelchat, where the prosecutor knew there was no evidence to support the indictment. Here, there was sufficient evidence, even without the videotape. The court emphasized that after a guilty plea, the sufficiency of the evidence before the Grand Jury cannot be challenged.