People v. Ramsay

Summary

The New York Appellate Division, Second Department, affirmed two judgments convicting Orlando Ramsay of multiple controlled-substance, weapons, firearm, drug-paraphernalia, conspiracy, and major-trafficker offenses following guilty pleas. The court held that his challenges to the voluntariness of his pleas were unpreserved and, alternatively, meritless, and that his ineffective-assistance claim was forfeited in part and otherwise without merit.

Holdings

1. A defendant's claim that a guilty plea was not knowing, voluntary, and intelligent is unpreserved when the defendant did not move to withdraw the plea or otherwise raise the issue in the trial court.
2. The record demonstrated that Ramsay's guilty pleas were knowing, voluntary, and intelligent.
3. By pleading guilty, Ramsay forfeited ineffective-assistance claims that did not directly involve the plea-negotiation process or sentencing; in any event, his ineffective-assistance claim was meritless.

Questions Presented

1. Whether Ramsay's challenge to the knowing, voluntary, and intelligent nature of his guilty pleas was preserved for appellate review or fell within an exception to the preservation requirement.
2. Whether the record demonstrated that Ramsay's guilty pleas were knowing, voluntary, and intelligent.
3. Whether Ramsay's guilty plea forfeited his ineffective-assistance claim except to the extent it directly concerned plea negotiations or sentencing, and whether the remaining ineffective-assistance claim had merit.

Disposition

affirmed