People v. Madison

Summary

The Appellate Division, Second Department, affirmed the amended judgment convicting Darrel D. Madison of criminal possession of a controlled substance in the third degree and animal fighting following his guilty plea. The court held that the plea was knowing, voluntary, and intelligent and that Madison was not denied effective assistance of counsel.

Holdings

1. A defendant's challenge to the voluntariness of a guilty plea based on misinformation of which the defendant had no knowledge at the time may be reviewed on appeal even when the defendant did not move to withdraw the plea or otherwise raise the issue before the trial court.
2. Madison's guilty plea was entered knowingly, voluntarily, and intelligently.
3. Madison was not deprived of the effective assistance of counsel in connection with plea negotiations or sentencing.
4. By pleading guilty, Madison forfeited ineffective-assistance claims that did not directly involve the plea-negotiation process or sentence.

Questions Presented

1. Whether Madison's guilty plea was invalid because he was allegedly misinformed about the legality of the promised sentence.
2. Whether the challenge to the voluntariness of the plea was preserved despite Madison's failure to move to withdraw the plea or otherwise raise the issue in County Court.
3. Whether Madison was deprived of the effective assistance of counsel in connection with plea negotiations and sentencing.
4. Whether pleading guilty forfeited ineffective-assistance claims unrelated to the plea-negotiation process and sentence.

Disposition

affirmed