New York Law Review

Tag: People v. La Ruffa

  • People v. La Ruffa, 37 N.Y.2d 58 (1975): Waiver of Double Jeopardy Defense by Guilty Plea

    37 N.Y.2d 58 (1975)

    A defendant, represented by counsel, who pleads guilty to a lesser charge after a trial has begun, waives the right to assert a double jeopardy defense, unless the guilty plea was induced by prosecutorial vindictiveness or other unconstitutional factors affecting the plea itself.

    Summary

    La Ruffa was initially indicted for first-degree murder, convicted of second-degree murder, and then retried for first-degree murder after his initial conviction was reversed. During the second trial, he pleaded guilty to second-degree murder. He later argued that the second trial for first-degree murder violated his double jeopardy rights. The New York Court of Appeals held that La Ruffa waived his double jeopardy defense by pleading guilty, distinguishing the case from *Blackledge v. Perry* where prosecutorial vindictiveness was a factor. The court reasoned that double jeopardy is a waivable defense and the guilty plea, made with counsel, constituted such a waiver in the absence of vindictiveness or coercion.

    Facts

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    La Ruffa was indicted for first-degree murder.
    At trial, he was convicted of second-degree murder.
    The second-degree murder conviction was reversed on appeal.
    He was retried on the original first-degree murder indictment.
    During the second trial, after the prosecution rested, he pleaded guilty to second-degree murder.
    He later claimed the retrial on the first-degree murder charge violated his double jeopardy rights.

    Procedural History

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    Original conviction for second-degree murder was reversed.
    Second trial occurred; La Ruffa pleaded guilty to second-degree murder.
    La Ruffa appealed, arguing a double jeopardy violation.
    The New York Court of Appeals initially affirmed the conviction.
    The U.S. Supreme Court remanded the case for reconsideration in light of *Blackledge v. Perry*.
    On reargument, the New York Court of Appeals adhered to its original decision of affirmance.

    Issue(s)

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    Whether a defendant waives his double jeopardy defense by pleading guilty to a lesser charge after a trial has commenced.

    Holding

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    No, the original decision of affirmance is adhered to. A defendant, with the advice of counsel, waives his double jeopardy defense by pleading guilty to a lesser charge unless the plea was the product of prosecutorial vindictiveness or the plea proceedings were directly affected by antecedent unconstitutionality.

    Court’s Reasoning

    The court distinguished this case from *Blackledge v. Perry*, emphasizing that *Blackledge* was grounded in due process concerns related to prosecutorial vindictiveness (escalating charges in response to the defendant’s exercise of appeal rights), which was absent in La Ruffa’s case. The court stated that “*Blackledge*, a due process holding, does not change this. While the practical effect of a double jeopardy defense may be to prevent a trial from taking place, it must first be affirmatively raised.” The court relied on *Tollett v. Henderson* and reiterated the principle that a guilty plea, entered knowingly and intelligently with the advice of counsel, generally waives the right to challenge prior constitutional deprivations. The court also emphasized that the plea was entered “in accordance with the then existing constitutional law of double jeopardy.” Absent vindictiveness or some other factor rendering the plea involuntary, the defendant’s plea constituted a waiver of his double jeopardy claim. The court noted that double jeopardy rights are waivable if not timely asserted. The court held that before a guilty plea will not work a waiver, there must be or have been a vindictive or retaliatory escalation of crime charged or sentence for a defendant who pursued his constitutional rights, a circumstance totally absent here.

  • People v. La Ruffa, 37 N.Y.2d 58 (1975): Waiver of Double Jeopardy Through Guilty Plea

    People v. La Ruffa, 37 N.Y.2d 58 (1975)

    A defendant’s knowing and intelligent guilty plea, made with advice of counsel, constitutes a waiver of their right against double jeopardy, even if subsequent legal developments expand that right retroactively.

    Summary

    La Ruffa was initially convicted of second-degree murder, but that conviction was overturned. He was retried for first-degree murder. During the second trial, La Ruffa, with counsel, pleaded guilty to second-degree murder. Years later, he sought to vacate the conviction, arguing double jeopardy because he was retried on the original first-degree murder charge after initially being convicted of a lesser charge in the first trial. The court held that La Ruffa’s guilty plea waived his double jeopardy claim, even though the legal understanding of double jeopardy had evolved since his plea. The court emphasized the importance of finality in convictions resulting from valid guilty pleas.

    Facts

    La Ruffa was indicted for first-degree murder in 1952 and convicted of second-degree murder. His conviction was overturned on appeal, and a new trial was ordered. In 1957, during his retrial on the original first-degree murder indictment, La Ruffa, with advice of counsel, withdrew his not guilty plea and pleaded guilty to second-degree murder. He later attempted to withdraw his plea, claiming he was in a “bad state of mind,” but the motion was denied. No appeal was taken at that time.

    Procedural History

    In 1970, a coram nobis application led to the 1957 judgment being vacated due to a deprivation of the right to appeal. La Ruffa was resentenced nunc pro tunc as of April 4, 1957. On appeal, he argued double jeopardy. The Appellate Division affirmed the conviction, holding that the guilty plea waived the double jeopardy claim. This appeal followed.

    Issue(s)

    Whether a defendant’s knowing and intelligent guilty plea to a lesser charge constitutes a waiver of a double jeopardy claim, precluding him from later asserting that claim based on subsequent retroactive expansions of double jeopardy protections.

    Holding

    Yes, because a guilty plea, entered knowingly and intelligently with advice of counsel, constitutes a waiver of the right not to be twice subjected to the risk of punishment for the same offense, even if the constitutional law regarding double jeopardy evolves retroactively after the plea.

    Court’s Reasoning

    The court reasoned that while the Fifth Amendment’s double jeopardy clause applies to the states via the Fourteenth Amendment, and prevents retrying a defendant for a crime they were implicitly acquitted of by a conviction on a lesser offense, these developments in double jeopardy law occurred *after* La Ruffa’s guilty plea. The court stated, “When a defendant admits his guilt and consents to the entry of judgment against him, he does so under the law then existing.” It is not contended that the plea was involuntary or unintelligent. The court emphasized the importance of finality in convictions. Quoting Brady v. United States, 397 U. S. 742, 757; McMann v. Richardson, 397 U. S. 759, 773-774 the State has a legitimate interest in maintaining the finality of convictions attributable to guilty pleas valid under constitutional standards existent at the time. Because there was no claim of duress, coercion or lack of awareness, the negotiated plea, made with the advice of competent counsel in light of the then existing law, should not be set aside merely because of a subsequent change in double jeopardy law.