People v. Brown, 14 N.Y.3d 113 (2010)

A guilty plea conditioned on a furlough to visit a seriously ill family member requires special scrutiny to ensure it is voluntary, knowing, and intelligent; a hearing is required where the record raises a legitimate question about voluntariness.

Summary

Defendant Brown pleaded guilty to robbery and grand larceny in exchange for a 2-to-4-year sentence and a three-week furlough to visit his comatose son. He later moved to withdraw the plea, arguing duress due to his son’s condition. The trial court denied the motion without a hearing, and the Appellate Division affirmed. The New York Court of Appeals reversed, holding that the circumstances raised a genuine question about the plea’s voluntariness, necessitating an evidentiary hearing. The Court emphasized the need for careful scrutiny of pleas conditioned on furloughs for family visitation.

Facts

Defendant was arrested and indicted for robbery and grand larceny and held on $10,000 bail. While in custody, his son was hospitalized in a coma due to gunshot wounds. At the initial court appearance, the court presented a plea deal: a guilty plea to both counts in exchange for a 2-to-4-year sentence and a three-week furlough to see his son. The court was aware that Brown was especially interested in the furlough. Prior to the plea, Brown’s request to visit his son in the hospital while in custody was denied. After a brief colloquy about rights, Brown pleaded guilty and was released on his own recognizance for the furlough.

Procedural History

After surrendering following the furlough, Brown moved to withdraw his guilty plea, claiming duress. The trial court denied the motion without a hearing. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.

Issue(s)

Whether the trial court erred in denying defendant’s motion to withdraw his guilty plea without holding an evidentiary hearing, given his claim that the plea was involuntary due to duress related to his son’s medical condition and the grant of a furlough to visit him.

Holding

Yes, because the circumstances surrounding the plea, including the furlough and the defendant’s detailed allegations of duress, raised a legitimate question about the plea’s voluntariness that required an evidentiary hearing to resolve.

Court’s Reasoning

The Court of Appeals emphasized that a guilty plea must be entered voluntarily, knowingly, and intelligently, representing an informed choice among valid alternatives. While the decision to grant a hearing on a motion to withdraw a plea rests largely in the trial court’s discretion, a hearing is required when the record raises a legitimate question about the plea’s voluntariness. The court distinguished this case from People v. Fiumefreddo, 82 N.Y.2d 536 (1993), noting that unlike Fiumefreddo, here, there was no indication of extended negotiations or sufficient time for Brown to consider alternatives. The trial court failed to inquire about the impact of the furlough on Brown’s decision or whether the plea was truly voluntary. Brown provided detailed allegations of duress, which the trial court disregarded, relying solely on Brown’s admission of guilt. The court noted, “[t]he court’s statement that defendant was ‘interested in taking the plea if I were to give [him] a furlough’ suggests that the court itself was aware of the central influence the furlough had on defendant’s decision to plead guilty.” The denial of Brown’s prior request to visit his son further supported his claim of duress. The Court clarified that pleas conditioned on furloughs are not per se invalid but require “special scrutiny.” The Court held that “so long as the totality of the circumstances reveals that the plea is voluntarily, knowingly and intelligently made, it will be upheld.” In this instance, an evidentiary hearing was necessary to determine voluntariness.