People v. Minaya, 54 N.Y.2d 360 (1981)

A court retains inherent power to correct clerical errors in sentencing to reflect the original intent and plea agreement, even after the sentence has commenced, provided the correction aligns with the defendant’s understanding and the court’s initial agreement.

Summary

Minaya pleaded guilty to attempted robbery in exchange for an agreed-upon sentence of 0 to 8 years. At sentencing, the court mistakenly stated a sentence of 3 years. Upon realizing the error, the court corrected the sentence to 8 years. The New York Court of Appeals held that the trial court acted properly in correcting the sentencing error. The court reasoned that the correction reflected the original plea agreement and intent, and the defendant was aware of the agreed-upon sentence. The court’s inherent power to correct its records extends to sentencing errors, especially when enforcing a valid plea bargain. The court held that correcting this type of error did not violate double jeopardy principles.

Facts

The defendant was indicted for first-degree robbery. As part of a plea bargain, Minaya agreed to plead guilty to attempted robbery in the first degree in exchange for a sentence of 0 to 8 years. During the plea and sentencing proceedings, the court and counsel acknowledged the plea agreement. However, when formally pronouncing the sentence, the court mistakenly stated a sentence of three years instead of eight.

Procedural History

The prosecutor discovered the sentencing discrepancy and requested the sentencing judge to resettle the record to reflect the negotiated sentence of eight years. The trial court admitted the error and corrected the sentence to eight years. The Appellate Division reversed, reinstating the three-year sentence, arguing that the correction violated the prohibition against changing sentences under CPL 430.10. The People appealed to the New York Court of Appeals.

Issue(s)

Whether a court may correct a sentencing error to reflect the original plea agreement, even after the initial (incorrect) sentence has commenced, without violating CPL 430.10 or the defendant’s double jeopardy rights.

Holding

Yes, because courts possess the inherent power to correct clerical errors in their records to conform to the truth, and this power extends to sentencing errors, especially when the correction aligns with a valid plea agreement. Further, correcting this type of error does not violate double jeopardy principles.

Court’s Reasoning

The Court of Appeals emphasized that courts have the inherent power to correct clerical errors in their records to ensure they reflect the truth, citing Bohlen v. Metropolitan El. Ry. Co. This power applies to criminal and civil cases, including sentencing errors, as established in People ex rel. Hirschberg v. Orange County Ct. The court distinguished between correcting an error and impermissibly changing a valid sentence. While CPL 430.10 prohibits changing a sentence once the term has commenced, it doesn’t eliminate the court’s power to correct errors or mistakes. The court found it evident that the trial court’s misstatement was an inadvertent error, and the correction reflected the original plea agreement, which all parties understood. The court stated, “[T]here is no reason why the court’s inherent power to correct its own mistakes generally should not permit the court to correct the particular error that occurred during sentencing in this case.”

Addressing the double jeopardy argument, the court cited United States v. Di Francesco, noting the Supreme Court rejected the idea that a sentence, once pronounced, has constitutional finality. The court found no statutory prohibition against correcting sentencing errors and concluded that the defendant’s hope that the error would be uncorrectable was unfounded. The court further reasoned that enforcing the original plea agreement did not violate the double jeopardy clause. The court stated, “To the extent the defendant may actually have entertained the hope that such an obvious error would be uncorrectable once he reached State prison, it was not founded on any authoritative pronouncement to that effect from this court or the Legislature.”