People v. Ariyarajah

Summary

The Appellate Division, Second Department affirmed judgments convicting Vignendra Ariyarajah of first-degree assault and second-degree health care fraud following guilty pleas. The court held that the Supreme Court properly denied his motion to withdraw the pleas without a hearing because the pleas were knowing, voluntary, and intelligent, and his coercion and ineffective-assistance claims lacked merit. The court also determined that he was properly advised of the immigration consequences of the pleas and failed to establish prejudice.

Holdings

1. The Supreme Court properly denied the defendant's motion to withdraw his guilty pleas because the record showed that the pleas were knowingly, voluntarily, and intelligently entered and did not establish innocence, fraud, mistake, coercion, or involuntariness.
2. The defendant failed to establish ineffective assistance or prejudice because, even if counsel did not independently advise him about immigration consequences, the Supreme Court properly provided that advice, and there was no reasonable probability that the defendant would have rejected the plea agreements and proceeded to trial.

Questions Presented

1. Whether the Supreme Court improvidently exercised its discretion by denying without a hearing the defendant's motion under CPL 220.60(3) to withdraw his guilty pleas.
2. Whether alleged coercion or misleading advice by defense counsel required withdrawal of the pleas.
3. Whether defense counsel's alleged failure to advise the defendant about immigration consequences constituted ineffective assistance under the United States Constitution and prejudiced the defendant.

Disposition

affirmed