21 N.Y.2d 447 (1968)

A guilty plea made by a defendant at a preliminary hearing before a magistrate, who lacks jurisdiction to accept such a plea, is inadmissible as evidence against the defendant in a subsequent trial.

Summary

The defendant appealed the denial of his application for a writ of error coram nobis. The Court of Appeals affirmed the denial, holding that a guilty plea made at a preliminary hearing before a magistrate in 1946 could not have been used against him at trial. At the time of the conviction, magistrates lacked the jurisdiction to accept guilty pleas; their role was limited to determining whether to hold the accused for grand jury action or discharge them. Therefore, any admission made at the preliminary hearing, whether a plea or incriminating statement, would be inadmissible. The court emphasized that the plea was not used against the defendant, but even if it had been, the conviction would have been reversed.

Facts

The defendant was convicted in 1947. Prior to the trial, the defendant entered a guilty plea during a preliminary hearing before a magistrate.

The magistrate’s role at the preliminary hearing was to determine if the accused should be held for action by the grand jury or discharged.

The defendant later applied for a writ of error coram nobis, which was denied.

Procedural History

The defendant applied for a writ of error coram nobis, which was denied by the Supreme Court Justice. The denial was appealed and affirmed by the Court of Appeals.

Issue(s)

Whether a guilty plea made by the defendant at a preliminary hearing before a magistrate, who lacked jurisdiction to accept such a plea, is admissible as evidence against the defendant in a subsequent trial.

Holding

No, because at the time of the defendant’s conviction, a magistrate holding a preliminary hearing lacked the jurisdiction to accept a plea of guilty; they could only decide whether the accused should be held for action by the grand jury or discharged.

Court’s Reasoning

The Court reasoned that because the magistrate lacked jurisdiction to accept a guilty plea, any admission made during the preliminary hearing could not be used against the defendant. The court stated, “If, on a record such as the one before us, an accused, nevertheless, made an admission upon the preliminary hearing — whether in the form of a plea or an incriminating statement — it could not later be used against him.” The court emphasized the longstanding rule that such admissions are inadmissible, citing several prior cases. The court further stated that even if the plea had been used against the defendant at trial, the resulting conviction would have been reversed. The court distinguished the case from People v. Steinmetz, noting that in Steinmetz, the defendant had pleaded guilty to the indictment in the court where the case was to be tried, not at a preliminary hearing before a magistrate. The court thus reinforced the principle that a magistrate’s lack of jurisdiction over guilty pleas renders such pleas inadmissible in subsequent trials. This rule protects defendants from being prejudiced by statements made in a setting where they may not fully understand the implications of their admissions. The court also noted, “In this State at the time the defendant was convicted (in 1947), as well as at the present time, a magistrate holding a preliminary hearing was without jurisdiction to accept a plea of guilty and could only decide whether the accused should be held for action by the grand jury or discharged (Code Crim, Pro., §§ 188-221-b).”