21 N.Y.3d 876 (2013)
When a guilty plea is induced by a specific promise or representation regarding the length of a sentence, and that promise is later undermined by subsequent events, the defendant may be entitled to withdraw the plea.
Summary
William Monroe pleaded guilty to conspiracy based on a judge’s representation that it would extend his minimum prison term by only 1.5 years, running concurrently with his existing sentences. Subsequently, Monroe’s original drug sentences were reduced under the Drug Law Reform Act, which effectively doubled the gap between the minimum terms of incarceration to three years. Monroe sought to withdraw his conspiracy plea, arguing it was unknowing due to the changed sentencing landscape. The New York Court of Appeals held that Monroe’s plea was induced by the judge’s specific representation and that he should be allowed to withdraw his plea.
Facts
In 2005, William Monroe pleaded guilty to drug offenses and was sentenced to concurrent indeterminate terms of 4.5 to 9 years. While incarcerated, he was indicted on conspiracy and drug charges. In 2007, Monroe pleaded guilty to conspiracy in exchange for a 6-to-12-year indeterminate sentence, meant to run concurrently. At the plea hearing, the judge stated this would effectively add 1.5 years before parole eligibility, which Monroe acknowledged understanding. Monroe was making progress in prison programs and expected parole at his earliest eligibility date.
Procedural History
Monroe applied for resentencing on his initial drug convictions under the Drug Law Reform Act of 2009 (DLRA). The resentencing court granted his application in 2010, reducing his indeterminate sentences to determinate sentences of three years, followed by post-release supervision. Consequently, Monroe moved to vacate his conspiracy plea, arguing it was unknowing because the DLRA resentencing altered the basis on which he entered the plea. The Supreme Court denied his motion, and the Appellate Division affirmed. The Court of Appeals reversed the lower courts’ rulings.
Issue(s)
Whether a defendant should be allowed to withdraw a guilty plea when the plea was induced by a specific representation about the length of the sentence, and subsequent changes to other sentences undermine the basis of that representation.
Holding
Yes, because the defendant’s plea to the conspiracy count was induced by the judge’s specific representation regarding the length of the sentence, and it cannot be said that the defendant would have pleaded guilty absent this assurance.
Court’s Reasoning
The Court of Appeals reasoned that Monroe’s guilty plea was directly influenced by the judge’s assurance that the conspiracy sentence would only extend his minimum incarceration by 1.5 years. The subsequent reduction of his original drug sentences under the DLRA significantly altered the sentencing landscape, effectively negating the benefit Monroe anticipated from the plea bargain. The court cited People v. McConnell, stating that “when a guilty plea has been induced by an unfulfilled promise either the plea must be vacated or the promise honored, but . . . the choice rests in the discretion of the sentencing court.” Given that Monroe demonstrably aimed for the earliest possible release, the court found it improbable he would have pleaded guilty without the judge’s specific representation. The court remitted the case to the Supreme Court, granting the defendant the opportunity to withdraw his plea. This decision emphasizes the importance of accurate and reliable sentencing information when accepting guilty pleas, particularly when the sentence is part of a plea agreement. It also underscores that unforeseen changes in related sentences can invalidate the foundation of a guilty plea, requiring the court to allow its withdrawal.