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Keywords

defendanthearingtrialpleaprosecutorgrand juryhearsayguilty plea

defendantlitigationhearingpleaprosecutorgrand juryhearsayguilty plea

Related Cases

People v. Hansen, 95 N.Y.2d 227, 738 N.E.2d 773, 715 N.Y.S.2d 369, 2000 N.Y. Slip Op. 08893

Facts

The case arose when the complainant, Harold Stickney, reported seeing the defendant on his property attempting to break in. Stickney's wife called 911 after hearing noises, and upon confronting the defendant, a struggle ensued. The police apprehended the defendant, who claimed he was there to shovel snow. During the grand jury proceedings, the prosecutor played a videotape that included hearsay evidence, which the defendant later contested as inadmissible.

During the Grand Jury presentation, the complainant, Harold Stickney, testified that shortly after midnight his wife awoke him after hearing noises outside their home, and called 911; that he saw defendant on their back porch holding a snow shovel; that he watched as defendant unsuccessfully tried to open the sliding glass door to the house, then kicked it in; and that, after pointing an antique gun at defendant, the two struggled and the police arrived.

Issue

Whether a defendant who pleaded guilty forfeited the right to contend that the fact-finding process of the Grand Jury was impaired by the prosecutor's introduction of inadmissible hearsay.

The issue is whether a defendant who pleaded guilty forfeited the right to contend that the fact-finding process of the Grand Jury, culminating in an indictment against him, was impaired by the prosecutor's introduction of inadmissible hearsay.

Rule

A guilty plea generally marks the end of a criminal case and waives the right to review claims related to rights that were deprived before the plea was entered.

A plea of guilty, as we have repeatedly observed, generally marks the end of a criminal case, not a gateway to further litigation.

Analysis

The court determined that the defendant's claim regarding the hearsay evidence did not survive his guilty plea. It emphasized that a guilty plea encompasses a waiver of specific rights attached to trial, including the right to challenge evidentiary issues that do not implicate the integrity of the process. The court found that the grand jury had sufficient evidence to support the indictment, and the introduction of the hearsay did not invalidate the proceedings.

Defendant contends that his guilty plea did not “waive” his right to seek dismissal of the indictment on the ground that the prosecutor, by showing portions of the videotaped reporter's remarks, impaired the integrity of the Grand Jury proceeding.

Conclusion

The court affirmed the Appellate Division's decision, concluding that the defendant's guilty plea forfeited his right to challenge the grand jury proceedings.

Accordingly, the order of the Appellate Division should be affirmed.

Who won?

The People (State of New York) prevailed because the court found that the defendant's guilty plea waived his right to contest the grand jury's proceedings.

Defendant's reliance on People v. Pelchat, 62 N.Y.2d 97, 476 N.Y.S.2d 79, 464 N.E.2d 447, is misplaced.

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Related Cases

People v. Hammond, 22 Cal.App.4th 1611, 28 Cal.Rptr.2d 180

Fulcher v. State, 633 P.2d 142

Gut v. State of Minnesota, 76 U.S. 35, 1869 WL 11595, 19 L.Ed. 573, 9 Wall. 35

People v. Curtis, 681 P.2d 504

Burger v. Kemp, 483 U.S. 776, 107 S.Ct. 3114, 97 L.Ed.2d 638, 55 USLW 5131