New York Court of Appeals

The People of the State of New York, Appellant v. Christian Williams, Respondent

April 5, 201627 N.Y.3d 212

Summary

The New York Court of Appeals reversed the Appellate Division and remanded the case, holding that the defendant failed to preserve his claim challenging the validity of his guilty plea and therefore the appellate court could not review the claim. The Court explained that the preservation rule applies unless the defendant had no practical ability to object, and found that the defendant had several opportunities to raise the issue before sentencing. A dissent argued that the preservation rule should not bar review because the error was undiscoverable and the plea was induced by an illegal sentencing promise.