People v. Meddaugh
150 A.D.3d 1545
| N.Y. App. Div. | 2017Background
- In Dec. 2013 defendant Meddaugh, on parole, was indicted on 11 counts (drug sale, possession, conspiracy).
- In Mar. 2014 she pleaded guilty pursuant to a negotiated plea to one count of criminal sale of a controlled substance in the third degree and agreed to an appeal waiver.
- County Court sentenced her, as a second felony offender, to 7 years’ prison plus 2 years postrelease supervision, consistent with the plea agreement.
- The record did not contain a written, signed appeal waiver nor did the court explain the distinct significance of an appeal waiver on the record.
- Meddaugh challenged her plea and sentence on direct appeal, asserting: (1) the appeal waiver was invalid; (2) her plea was involuntary because of alleged unfulfilled promises (facility placement and parenting time); (3) ineffective assistance of counsel for not seeking judicial diversion; and (4) the sentence was harsh and excessive.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Meddaugh) | Held |
|---|---|---|---|
| Validity of appeal waiver | Waiver bars appellate challenges | Waiver invalid because court failed to explain its separate significance and no signed written waiver appears | Waiver invalid; record lacks written waiver and court did not explain waiver’s separate significance |
| Voluntariness of plea based on promises | Plea colloquy reflects understanding of terms; no enforceable off‑record promise | Plea induced by unfulfilled promises about facility placement and ability to remain with newborn | Plea voluntary; colloquy refutes off‑the‑record promises and defendant knew plea terms |
| Ineffective assistance for not seeking judicial diversion | Counsel negotiated favorable plea resolving 11 counts; diversion discretionary | Counsel was deficient for not advising/requesting CPL 216 judicial diversion | Claim rejected on the record: counsel provided meaningful representation and diversion is discretionary, not guaranteed |
| Excessiveness of sentence | Sentence followed plea agreement and was within court’s discretion | Sentence harsh given age, mental health, pregnancy, alleged diversion eligibility | Sentence not harsh or excessive; no extraordinary circumstances or abuse of discretion |
Key Cases Cited
- People v. Lopez, 6 NY3d 248 (NY 2006) (appeal waivers must be explained as distinct from rights forfeited by a guilty plea)
- People v. Collier, 22 NY3d 429 (NY 2013) (pleas induced by unfulfilled promises must be vacated or promises honored)
- People v. Selikoff, 35 NY2d 227 (NY 1974) (off‑the‑record promises not entitled to judicial recognition in plea context)
- Matter of Benjamin S., 55 NY2d 116 (NY 1982) (court will not enforce off‑the‑record plea promises)
- People v. Frederick, 45 NY2d 520 (NY 1978) (same principle regarding plea promises)
- People v. Ramos, 135 AD3d 1234 (3d Dep’t 2016) (discusses meaningful representation standard in plea context)