New York Court of Appeals

The People of the State of New York, Respondent v. Bart Alexander, Appellant

March 21, 200297 N.Y.2d 482

Summary

The Court of Appeals affirmed the Appellate Division’s order upholding the conviction, holding that the trial court did not abuse its discretion in denying the defendant’s motion to withdraw his Alford plea. The majority emphasized that competence, voluntariness, and the lack of a factual basis for an Alford plea do not, by themselves, require withdrawal, and that the victim’s desire to drop the charges is insufficient. Justice Smith dissented, arguing that the trial court should have ensured competency at the time of the plea and required a factual basis for the conviction.