People v. Taylor, 31 N.Y.3d 937 (2018)
When a defendant’s plea allocution raises significant doubt about their guilt or the voluntariness of their plea, especially regarding the element of intent due to potential mental disease or defect, the trial court has a duty to inquire further to ensure the guilty plea is knowing and voluntary.
Summary
Taylor was indicted for second-degree murder for killing his father. He had a history of mental illness. After being declared competent to stand trial, he pleaded guilty to first-degree manslaughter, asserting he was “in a psychotic state” and “hearing voices” at the time of the crime. The Appellate Division reversed the conviction, finding that the plea allocution raised doubts as to his guilt due to the potential negation of the intent element of manslaughter. The Court of Appeals affirmed, holding that the trial court failed in its duty to adequately inquire whether Taylor’s waiver of a potential insanity defense was knowing and voluntary, given his statements during the plea allocution.
Facts
Taylor was indicted for the second-degree murder of his father, allegedly committed by stabbing him and striking him in the head.
Taylor had a documented history of mental illness and had been hospitalized for psychiatric treatment for much of the year preceding his father’s death.
During the plea colloquy, Taylor stated he was “in a psychotic state” and “hearing voices” on the day of the crime, and had not taken his prescribed medication for several days.
Procedural History
Taylor was declared competent to stand trial after psychiatric hospitalization.
He pleaded guilty to first-degree manslaughter in exchange for a determinate sentence of 25 years plus five years’ post-release supervision and a waiver of the right to appeal.
Taylor moved to withdraw his plea before sentencing, which the County Court denied.
The Appellate Division reversed Taylor’s conviction, holding that the plea allocution raised doubts as to his guilt and that the County Court failed to fulfill its duty to make further inquiry.
Issue(s)
Whether the trial court had a duty to inquire further into the defendant’s understanding of the implications of his guilty plea, given that his allocution raised the possibility that he lacked the requisite intent to commit the crime due to a mental disease or defect.
Holding
Yes, because when a defendant’s recitation of facts casts significant doubt upon their guilt or the voluntariness of the plea, the trial court has a duty to inquire further to ensure that the guilty plea is knowing and voluntary.
Court’s Reasoning
The Court of Appeals relied on the principles established in People v. Lopez, 71 N.Y.2d 662 (1988), and People v. Serrano, 15 N.Y.2d 304 (1965), which dictate that when a defendant’s statements during a plea allocution cast significant doubt upon their guilt, the trial court has a duty to inquire further to ensure the plea is knowing and voluntary. Here, Taylor’s statements about being “in a psychotic state” and “hearing voices” raised the possibility that he lacked the requisite intent to commit first-degree manslaughter due to a mental disease or defect, potentially establishing an insanity defense. The court stated that “[w]here the court fails in this duty and accepts the plea without further inquiry, the defendant may challenge the sufficiency of the allocution on direct appeal.”
The Court found that the County Court’s single question to Taylor, verifying that he discussed the potential defense with his attorney and chose not to assert it, was insufficient to meet the court’s obligation to ensure a knowing and voluntary plea. The Court emphasized the importance of ensuring that a defendant’s decision to waive a potentially viable insanity defense is an informed one. The court noted, “Vacatur is warranted where such doubt is raised and the trial court takes no or inadequate measures to resolve it and ensure that the defendant’s plea is knowing and voluntary.”