People v. Rios

Summary

The New York Court of Appeals holds that the People v. Lopez exception to the preservation requirement does not apply when a defendant challenges the factual basis of a guilty plea through statements made only at sentencing. Because Jonathan Rios did not move to withdraw his plea or vacate the judgment of conviction, the Court concludes that his challenge was unpreserved and affirms the Appellate Division. A concurrence would apply the exception but affirm on the ground that the sentencing court adequately inquired into Rios's understanding and voluntariness.

Holdings

1. Statements made at sentencing after acceptance of a guilty plea that challenge the factual basis of the plea do not trigger the People v. Lopez exception to the preservation requirement.
2. Because Rios neither moved to withdraw his plea nor moved to vacate the judgment of conviction, his challenge to the knowingness and voluntariness of the plea was unpreserved for appellate review.
3. People v. Beasley does not establish a standalone duty to inquire based solely on a defendant's recantation or challenge to guilt at sentencing after a valid plea has been accepted.
4. The sentencing court's inquiry sufficiently confirmed that Rios understood the charge and voluntarily reaffirmed his guilty plea.

Questions Presented

1. Whether the People v. Lopez exception to the preservation requirement applies when a defendant makes postplea statements at sentencing that challenge the factual basis of a previously entered guilty plea.
2. Whether Rios's challenge to the knowingness and voluntariness of his guilty plea was preserved without a motion to withdraw the plea or vacate the judgment of conviction.
3. Whether the sentencing court's inquiry adequately established that Rios understood the nature of the charge and voluntarily reaffirmed his guilty plea.

Disposition

affirmed