New York Court of Appeals
The People of the State of New York, Respondent v. Ian Clarke, Appellant
May 6, 199993 N.Y.2d 904
Summary
The Court affirmed the Appellate Division’s order, holding that the appellant’s challenge to the validity of his guilty plea was required to be preserved at the trial court and was not a “mode of proceedings” issue. The Court found the trial court’s ambiguous comment to be a mere mistake of language and declined to apply the narrow exception for unpreserved plea challenges.