People v. Keizer, 100 N.Y.2d 114 (2003)

A defendant’s valid guilty plea generally forfeits the right to challenge non-jurisdictional defects in the accusatory instrument or the plea proceedings, absent specific statutory authorization to the contrary.

Summary

This case addresses whether a defendant can challenge a conviction after pleading guilty, based on defects in the initial charges or plea bargain. In People v. Keizer, the defendant pleaded guilty to disorderly conduct after being charged with larceny. In People v. Pittman, the defendant pleaded guilty to disorderly conduct after being charged with drug possession based on an accusatory instrument that the defendant claimed was based on hearsay. The New York Court of Appeals held that in both cases, the guilty pleas forfeited the defendants’ rights to challenge their convictions based on non-jurisdictional defects. A valid guilty plea generally marks the end of a criminal case, and challenges related to factual guilt or statutory authorization are forfeited.

Facts

People v. Keizer: Morgan Keizer was charged with petit larceny and criminal possession of stolen property after allegedly attempting to steal books from a bookstore. He pleaded guilty to disorderly conduct.

People v. Pittman: Johnnie Pittman was charged with criminal possession of a controlled substance. The accusatory instrument stated it was based on the officer’s “own knowledge and on information and belief.” Pittman moved to dismiss, arguing it was impossible to determine which allegations were based on personal knowledge.

Procedural History

People v. Keizer: The Criminal Court accepted Keizer’s plea. Appellate Term affirmed. The New York Court of Appeals granted leave to appeal.

People v. Pittman: City Court denied Pittman’s motion to dismiss. Pittman pleaded guilty to disorderly conduct. Appellate Term reversed, dismissing the accusatory instrument as jurisdictionally defective. The New York Court of Appeals granted the People leave to appeal.

Issue(s)

1. In Keizer: Whether Criminal Court lacked jurisdiction to convict the defendant based on a plea of disorderly conduct when that offense was not charged in the complaint nor a lesser included offense.

2. In Pittman: Whether a purported hearsay defect in an accusatory instrument is non-jurisdictional and thus forfeited by a guilty plea.

3. In Pittman: Whether the defendant’s claim that his guilty plea to disorderly conduct was jurisdictionally defective because it was not a valid lesser included offense is forfeited.

Holding

1. In Keizer: No, because the court had jurisdiction over the defendant via the valid complaint, and the acceptance of the guilty plea did not abrogate that jurisdiction.

2. In Pittman: Yes, because hearsay defects in accusatory instruments are non-jurisdictional and waivable if not raised at trial.

3. In Pittman: Yes, because any claim that the disposition was not statutorily authorized is forfeited by his guilty plea.

Court’s Reasoning

The Court reasoned that a guilty plea generally marks the end of a criminal case. In Keizer, the court had jurisdiction to commence the criminal action via the misdemeanor complaint. The specific constitutional limitations restricting the plea process for felony charges are absent in misdemeanor cases. Any claim of error that the disposition was not statutorily authorized is forfeited by the guilty plea.

In Pittman, the Court relied on People v. Casey, holding that hearsay defects are nonjurisdictional and waivable if not raised at the trial level. The Court reasoned that a plea usually removes the issue of factual guilt, so whether a claim is forfeited depends on whether it relates to the factual elements of the crime or some other fundamental matter. By pleading guilty, the defendant cannot revisit the alleged hearsay defect as the claim is forfeited. The court emphasized that there is no mechanical rule that fixes when a claim is forfeited by a guilty plea, referencing People v Taylor, 65 NY2d at 5.

The Court also referenced People v Hansen, (95 NY2d 227 [2000]), where the court held that the defendant forfeited his right to raise a claim of improperly admitted evidence before the grand jury due to his guilty plea, characterizing that argument as “essentially relat[ing] to the quantum of proof required to satisfy the factual elements of the crimes considered by the Grand Jury”