People v. Knuckles, 74 N.Y.2d 866 (1989)

A defendant cannot challenge the constitutional validity of a prior conviction used as an aggravating element of a new crime through a motion in limine within the context of the new criminal action when other procedural avenues for challenging the prior conviction exist.

Summary

Knuckles was convicted of driving while intoxicated (DWI) in Nassau County. Because of a prior DWI conviction in Suffolk County, the Nassau County offense was treated as a felony under Vehicle and Traffic Law § 1192(5). Knuckles sought to challenge the constitutional validity of the Suffolk County conviction via a motion in limine in the Nassau County case. The New York Court of Appeals held that Knuckles could not challenge the prior conviction in this manner because other procedural vehicles existed to challenge the constitutional propriety of the guilty plea. Thus, a new, judicially created remedy was unnecessary.

Facts

Knuckles was arrested and convicted for DWI in Nassau County.

A prior DWI conviction in Suffolk County existed.

The Suffolk County conviction elevated the Nassau County DWI to a felony under Vehicle and Traffic Law § 1192(5).

Knuckles attempted to challenge the constitutional validity of the Suffolk County conviction via a motion in limine within the Nassau County criminal action.

Procedural History

The trial court denied Knuckles’ motion in limine.

Knuckles appealed, arguing that he was denied the opportunity to challenge the constitutional validity of his prior Suffolk County conviction.

The Appellate Division affirmed the trial court’s decision.

The New York Court of Appeals affirmed the Appellate Division’s order.

Issue(s)

Whether a defendant can challenge the constitutional validity of a prior conviction, used as an aggravating element of a new crime, by making a motion in limine within the context of the new criminal action.

Holding

No, because there already exist several procedural vehicles for challenging the constitutional propriety of guilty pleas under the facts presented. Thus, a new, judicially created, remedy is not needed.

Court’s Reasoning

The Court of Appeals declined to fashion a special judicial procedure for contesting the constitutionality of prior convictions used to aggravate a new crime. The Court reasoned that existing procedural vehicles already adequately address the defendant’s due process concerns. The Court noted that the Legislature had not provided for such a motion. The Court also distinguished the request from legislatively created procedures, such as suppression motions (CPL art. 710) and challenges to predicate felonies for enhanced sentencing (CPL 400.21). Because adequate remedies already existed, the Court found no need to create a new judicial remedy. The court cited People v. Lopez, 71 N.Y.2d 662, and People v. Bachert, 69 N.Y.2d 593, in support of its conclusion. The court concluded that “a new, judicially created, remedy is not needed in this situation to ensure protection of the accused’s right to due process of law.”