People v. Kiriakos

2025 NY Slip Op 07408 (Supreme Court of the State of New York Appellate Division Second Judicial Department 2025) · Supreme Court of the State of New York, Appellate Division, Second Judicial Department · December 31, 2025 · No. 2019-05508

Summary

The New York Supreme Court, Appellate Division, Second Department, affirmed a judgment convicting Faddy I. Kiriakos of criminal mischief in the fourth degree and resisting arrest following his guilty plea. The court held that his challenge to the validity of the plea was unpreserved and, in any event, that the record demonstrated the plea was entered intelligently, knowingly, and voluntarily.

Court
Supreme Court of the State of New York, Appellate Division, Second Judicial Department
Writing for the Court
Mark C. Dillon, J.P.; Angela G. Iannacci, J.; Deborah A. Dowling, J.; James P. McCormack, J.
Jurisdiction
Supreme Court of the State of New York, Appellate Division, Second Department
Decision date
December 31, 2025
Docket number
2019-05508
Procedural posture
Defendant appealed from a County Court judgment convicting him, upon his plea of guilty, of criminal mischief in the fourth degree and resisting arrest and imposing sentence.
Standard of review
The challenge to the validity of the guilty plea was reviewed for preservation and, alternatively, on the record for whether the plea was entered intelligently, knowingly, and voluntarily.
Precedential value
Published
Parties
Faddy I. Kiriakos v. The People of the State of New York
Disposition
affirmed

Topics

criminal procedureplea bargainingpreservation of errorappellate procedure

Practice areas

criminal procedureappellate procedureguilty pleas

Questions Presented

  1. Whether defendant preserved his challenge to the validity of his guilty plea for appellate review.
  2. Whether, notwithstanding the lack of preservation, the record demonstrated that defendant entered his guilty plea intelligently, knowingly, and voluntarily.

Holdings

  1. A defendant's challenge to the validity of a guilty plea is unpreserved for appellate review when the defendant neither moves to withdraw the plea nor otherwise objects to its entry before sentencing.
  2. The record as a whole demonstrated that defendant entered his guilty plea intelligently, knowingly, and voluntarily.

Key quotations

In any event, the record as a whole demonstrates that the defendant entered his plea intelligently, knowingly, and voluntarily ([*1])

Factual background

Defendant pleaded guilty to criminal mischief in the fourth degree and resisting arrest. He did not move to withdraw his plea or otherwise object to its entry before the County Court imposed sentence.

Procedural history

The County Court, Westchester County, rendered judgment on April 8, 2019, after defendant pleaded guilty to criminal mischief in the fourth degree and resisting arrest. Defendant appealed, challenging the validity of his guilty plea. The Appellate Division affirmed.

Court Document

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