People v. Seeber, 34 N.Y.3d 1013 (2020)

A trial court does not abuse its discretion by denying a motion to withdraw a guilty plea without a hearing where the record demonstrates the plea was knowing, voluntary, and intelligent, and where the defendant fails to provide an affidavit supporting the motion or to address the court.

Summary

The New York Court of Appeals affirmed the Appellate Division’s decision, holding that the trial court properly denied the defendant’s motion to withdraw his guilty plea without a hearing. The defendant, convicted of second-degree murder, sought to withdraw his plea based on claims of family pressure, drug and alcohol use, and uncertainty about his intent. The Court found that the trial court fulfilled its duty to ensure the plea was knowing and voluntary. Because the defendant did not provide an affidavit, and the record indicated that the plea was knowing, voluntary and intelligent, the Court held that no hearing was required, and the trial court did not abuse its discretion.

Facts

The defendant pleaded guilty to second-degree murder. He had two alternative plea offers, which the court explained to him. During the plea allocution, the defendant indicated that he understood the plea options and had discussed the guilty plea with his counsel. Subsequently, the defendant, through his attorneys, moved to withdraw his guilty plea, citing pressure from family members, the defendant’s appearance on the day of the plea, and impairment due to alcohol and marijuana. The motion was supported by attorneys’ affirmations and a psychiatrist’s report, but not by an affidavit from the defendant. The trial court found that the plea was knowing and voluntary and denied the motion to withdraw the plea without a hearing.

Procedural History

The defendant was convicted of second-degree murder based on his guilty plea. The defendant moved to withdraw his guilty plea, which the trial court denied without a hearing. The Appellate Division affirmed the trial court’s decision. The defendant appealed to the New York Court of Appeals, which also affirmed.

Issue(s)

1. Whether the trial court abused its discretion by denying the defendant’s motion to withdraw his guilty plea without holding a hearing?

Holding

1. No, because the trial court properly determined that the guilty plea was knowing, voluntary, and intelligent based on the record.

Court’s Reasoning

The Court relied on the principle that “the nature and extent of the fact-finding inquiry rest[s] largely in the discretion of the Judge to whom the motion is made and a hearing will be granted only in rare instances.