People v. Robinson

Appellate Division of the Supreme Court of New York, Third Department · 2025 · Evidence

EvidenceGuilty pleasPost-conviction reliefGrand jury procedureIneffective assistance of counselguilty pleaunfulfilled promiseCASAT

Facts

Defendant agreed to plead guilty as charged in exchange for a total sentence of nine years in prison, five years of postrelease supervision, and a court order directing his enrollment in the comprehensive alcohol and substance abuse treatment (CASAT) program. County Court imposed the agreed prison sentence and directed CASAT enrollment. Defendant later moved under CPL 440.10, arguing among other things that his plea was involuntary and counsel was ineffective. The record showed that defendant was not enrolled in CASAT because he was not statutorily eligible for that program.

Issue

Whether defendant was entitled to vacatur of his guilty plea where the plea agreement included a promise that the court would order his enrollment in CASAT, but that promise could not be fulfilled because defendant was statutorily ineligible for the program. The court also addressed several waived or meritless grand jury and ineffective-assistance arguments.

Rule

A guilty plea induced by an unfulfilled promise either must be vacated or the promise honored. When the promised benefit is legally unavailable and the promise was part and parcel of the plea agreement, the plea must be vacated. Claims concerning the right to testify before the grand jury, constitutional speedy trial, and multiplicity are waived on direct appeal if the defendant failed to move to dismiss on those grounds, and unsupported CPL 440.10 ineffective-assistance claims may be denied without a hearing.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Albany, Marcus Vega agreed to plead guilty to burglary charges after the judge stated on the record that the court would order his placement in a prison parenting program. The promised program was available only to inmates convicted of designated family-offense-related crimes, and Marcus did not qualify under the statute.

If the parenting-program placement was an express part of the plea bargain and cannot legally be provided, what is the strongest argument for Marcus on appeal?

Explanation. The controlling rule is that a guilty plea induced by an unfulfilled promise either must be vacated or the promise honored. Where the promised benefit was part of the plea agreement and is legally unavailable, the promise cannot be honored, so vacatur is required. (Derived from People v. Robinson (n.d.).)