People v. Hill, 17 N.Y.3d 812 (2011)
A guilty plea is invalid if the defendant denies an essential element of the crime during the plea allocution, and the record does not establish that the defendant was aware of the nature and character of an Alford plea.
Summary
Defendant Hill pleaded guilty to first-degree manslaughter after initially being charged with second-degree murder. During the plea allocution, Hill insisted he did not intend to kill or harm his uncle, the victim. The trial court accepted the plea after further inquiry, but Hill later sought to withdraw it, arguing it was not knowing, voluntary, and intelligent. The New York Court of Appeals reversed the Appellate Division’s affirmation of the plea, holding that Hill’s denial of intent during the allocution was not adequately addressed, and the record failed to show he understood the nature of an Alford plea. The Court emphasized that Alford pleas should be rare and the product of a voluntary and rational choice based on strong evidence of guilt.
Facts
Hadji Hill stabbed his uncle in the chest with a switchblade knife during an argument in his apartment, resulting in his uncle’s death. Hill was arrested and charged with second-degree intentional murder. On the day of the scheduled jury trial, Hill offered to plead guilty to first-degree manslaughter. During the plea allocution, Hill stated he did not intend to kill or harm his uncle, claiming he only used the knife to keep his uncle away during a struggle.
Procedural History
The trial court accepted Hill’s guilty plea to first-degree manslaughter. Hill subsequently moved to withdraw his plea, arguing ineffective assistance of counsel. The trial court denied the motion and imposed the agreed-upon sentence. The Appellate Division affirmed the conviction, concluding that the trial judge made the requisite further inquiry and conducted a limited Alford colloquy. The New York Court of Appeals reversed, vacating the plea and remitting the case for further proceedings.
Issue(s)
Whether a guilty plea is valid when the defendant denies an essential element of the crime (intent) during the plea allocution, and the record does not demonstrate that the defendant understood the nature and consequences of an Alford plea.
Holding
No, because the defendant denied the intent element of first-degree manslaughter during the plea allocution, and the record does not establish that he was aware of the nature and character of an Alford plea.
Court’s Reasoning
The Court of Appeals reasoned that Hill’s denial of intent during the plea allocution was a critical deficiency that was not cured by the trial court’s further inquiry. While a court may accept an Alford plea even without a recitation of every essential element, such pleas are rare and require a voluntary and rational choice based on strong evidence of actual guilt. The Court stated, “Even absent a recitation as to every essential element, the court may still accept the plea—now an Alford plea…however, Alford pleas are—and should be—rare…and are allowed only when, as in Alford itself, [they are] the product of a voluntary and rational choice, and the record before the court contains strong evidence of actual guilt.” The Court found that the record did not establish Hill was aware of the nature and character of an Alford plea; he was not asked if he wished to plead guilty to avoid the risk of conviction on the more serious charge of second-degree murder. The Court concluded that Hill’s plea was not “the product of a voluntary and rational choice” because it appeared he believed his knowledge that the switchblade knife “could have caused damage” constituted an admission of guilt. Therefore, the guilty plea was deemed invalid.