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People v. Schmidli

Citations: 118 A.D.3d 1491; 987 N.Y.S.2d 540

Court: Appellate Division of the Supreme Court of the State of New York; June 20, 2014; New York; State Appellate Court

Narrative Opinion Summary

Defendant appeals a judgment from Niagara County Court, which convicted him of criminal possession of stolen property in the fourth degree based on his guilty plea. The court, led by Judge Matthew J. Murphy III, affirmed the judgment, rejecting the defendant's argument that his plea was not entered knowingly, voluntarily, or intelligently. The defendant claimed he did not admit to knowing the property was stolen during the plea allocution and asserted that the County Court improperly denied his motion to withdraw the plea on that basis. However, the court determined that this argument challenges the factual sufficiency of the plea allocution, which is covered by a valid waiver of the right to appeal. Relevant case law supports this view, citing precedents such as People v. Topolski, People v. Daniels, and People v. Villar. The decision was affirmed unanimously by Judges Smith, Centra, Carni, Whalen, and DeJoseph.

Legal Issues Addressed

Factual Sufficiency of Plea Allocution

Application: The court found that the defendant's claim of not admitting knowledge of the stolen nature of the property during the plea allocution was insufficient to withdraw the plea under the waiver of appeal.

Reasoning: The defendant claimed he did not admit to knowing the property was stolen during the plea allocution and asserted that the County Court improperly denied his motion to withdraw the plea on that basis.

Precedent and Case Law

Application: The court's decision was supported by precedents, illustrating consistency with prior rulings such as People v. Topolski, People v. Daniels, and People v. Villar.

Reasoning: Relevant case law supports this view, citing precedents such as People v. Topolski, People v. Daniels, and People v. Villar.

Validity of Guilty Plea

Application: The court affirmed that the defendant's guilty plea was entered knowingly, voluntarily, and intelligently, rejecting the defendant's contrary assertion.

Reasoning: The court, led by Judge Matthew J. Murphy III, affirmed the judgment, rejecting the defendant's argument that his plea was not entered knowingly, voluntarily, or intelligently.

Waiver of Right to Appeal

Application: The defendant's challenge to the factual sufficiency of the plea allocution was deemed covered by a valid waiver of the right to appeal, leading to the rejection of his motion to withdraw the plea.

Reasoning: However, the court determined that this argument challenges the factual sufficiency of the plea allocution, which is covered by a valid waiver of the right to appeal.