New York Court of Appeals

The People of the State of New York, Respondent v. Rasaun Sanders, Also Known as Boo Cracks, Appellant

June 9, 201525 N.Y.3d 337

Summary

The Court of Appeals affirmed the Appellate Division order upholding defendant's guilty-plea waiver of his right to appeal, holding that the plea colloquy—conducted largely by the prosecutor—together with defendant's age and extensive criminal history established a voluntary, knowing and intelligent waiver, which barred his challenge to the denial of his motion to suppress. The court reiterated that no particular litany or absolute minimum colloquy content is required, as waiver validity turns on the totality of the relevant facts and circumstances. Because the general appeal waiver was valid, the suppression challenge could not be heard. Judge Rivera dissented, contending that a defendant's criminal record alone cannot cure a deficient allocution, and would have remitted the matter for consideration of the merits of the suppression claim.