People v. Weems

2025 NY Slip Op 04403 · Appellate Division, Fourth Judicial Department · July 25, 2025 · No. 548 KA 24-00096

Summary

This Appellate Division, Fourth Department memorandum affirms the defendant's conviction for assault in the second degree following his guilty plea. The court holds that claims regarding alleged discovery violations and ineffective assistance of counsel are forfeited by the guilty plea. Additionally, the court declines to grant youthful offender status or exercise its interest of justice jurisdiction, finding the sentence was not unduly harsh or severe.

Court
Appellate Division, Fourth Judicial Department
Writing for the Court
BANNISTER, J.P.; MONTOUR; OGDEN; DELCONTE; KEANE
Jurisdiction
New York
Decision date
July 25, 2025
Docket number
548 KA 24-00096
Procedural posture
Appeal from conviction and sentence affirmed.
Standard of review
abuse of discretion
Precedential value
published
Parties
Malik M. Weems v. People of the State of New York
Disposition
affirmed

Topics

criminal procedureappellate procedureplea bargainingdiscovery criminal

Practice areas

criminal procedure

Questions Presented

  1. Whether the defendant's discovery‑violation claims are forfeited by his guilty plea.
  2. Whether an ineffective‑assistance claim survives a guilty plea absent a specific allegation that the plea was the product of counsel's deficient performance.
  3. Whether the trial court abused its discretion in declining to grant youthful‑offender status.
  4. Whether the imposed sentence is unduly harsh or severe.

Holdings

  1. The defendant's discovery‑violation claims are forfeited by his guilty plea.
  2. The ineffective‑assistance claim does not survive the guilty plea because the defendant did not allege that the plea bargaining process was infected by counsel's alleged poor performance.
  3. The trial court did not abuse its discretion in declining to grant youthful‑offender status.
  4. The sentence is not unduly harsh or severe.

Key quotations

[d]efendant's contention that defense counsel was ineffective does not survive his plea . . . inasmuch as defendant did not assert that the plea bargaining process was infected by [the] allegedly ineffective assistance or that defendant entered the plea because of [defense counsel's] allegedly poor performance (at 1)

Factual background

Defendant Malik M. Weems pleaded guilty to second‑degree assault. He asserted claims of discovery violations and ineffective assistance of counsel, and sought youthful‑offender status. The sentencing court imposed a term that the appellant argued was unduly harsh.

Procedural history

The Supreme Court of Ontario County, sitting as a trial court, entered a judgment on September 13, 2023 convicting the defendant, Malik M. Weems, of assault in the second degree after he entered a guilty plea. The defendant appealed to the Appellate Division, Fourth Department.

Court Document

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