1 N.Y.3d 532 (2003)
An appellate court lacks jurisdiction to hear an appeal from a trial court’s order when judgment has not yet been entered in the underlying case, regardless of whether the order is characterized as one concerning a motion to withdraw a plea or a motion to vacate a plea.
Summary
Defendant Huang sought to withdraw his guilty plea or, alternatively, vacate it, arguing his attorney misinformed him about his immigration status. The trial court granted the motion, treating it as both a motion to withdraw the plea and a motion to vacate. The People appealed, arguing the trial court lacked authority. The Appellate Division rejected Huang’s ineffective assistance claim on the merits. The Court of Appeals reversed, holding that because judgment hadn’t been entered, the Appellate Division lacked jurisdiction to hear the People’s appeal. The Court emphasized that appellate jurisdiction is contingent on a final judgment.
Facts
Defendant Huang pleaded guilty. After sentencing but before the entry of judgment, Huang moved to withdraw his plea, claiming his attorney provided incorrect information about his immigration status. Alternatively, he sought to vacate his plea under CPL 440.10(1). The trial court granted the motion, effectively giving the plea back to the defendant, and characterized the ruling as granting both a CPL 220.60(3) motion to withdraw and, in the alternative, a CPL 440.10 motion to vacate.
Procedural History
The People appealed the trial court’s decision to the Appellate Division. The Appellate Division addressed the merits of Huang’s ineffective assistance of counsel claim, rejecting it. Huang appealed to the New York Court of Appeals, arguing that the Appellate Division lacked jurisdiction because no final judgment had been entered in the case at the time of the People’s appeal to the Appellate Division.
Issue(s)
Whether the Appellate Division had jurisdiction to hear the People’s appeal from the trial court’s order when judgment had not been entered in the case.
Holding
No, because judgment had not been entered, the Appellate Division lacked jurisdiction to entertain the People’s appeal.
Court’s Reasoning
The Court of Appeals reasoned that the People’s appeal to the Appellate Division was improper because it sought review of a nonappealable order. The Court emphasized that under CPL 450.20, appellate jurisdiction is dependent on the existence of a judgment. Because judgment had not been entered at the time the People appealed the trial court’s decision, the Appellate Division lacked the power to hear the appeal. The Court stated, “In appealing trial court’s determination—whether properly made under CPL 220.60 (3), or, alternatively, not expressly authorized by the CPL—the People sought review of a nonappealable order. As the parties agree, moreover, judgment had not been entered, and thus no appeal could lie from the ‘alternative’ CPL 440.10 ruling. Accordingly, the Appellate Division had no jurisdiction to entertain the People’s appeal (see CPL 450.20).” This highlights the fundamental principle that appellate courts can only review final judgments or certain specifically enumerated non-final orders; absent a judgment, the appeal is premature. The decision underscores the importance of adhering to procedural rules governing appellate jurisdiction.