New York Court of Appeals

The People of the State of New York v. Reece Rudolph

June 27, 201321 N.Y.3d 497

Summary

The Court held that a sentencing court must determine whether an eligible youthful offender should receive youthful offender treatment, even when the defendant does not request consideration or purports to waive it during plea bargaining. It overruled the contrary precedent, reversed the Appellate Division, and remitted the case for a youthful offender determination; the defendant could not withdraw the guilty plea based on the ruling. Judge Graffeo concurred in the result but would permit a knowing and voluntary waiver of youthful offender status in a negotiated plea, while Judge Read, joined by Judge Pigott, dissented from overruling the prior statutory interpretation.