People v. Williams, 227 A.D.3d 480

Edward Williams was convicted in Bronx County Supreme Court of criminal possession of a weapon in the third degree, following a guilty plea.
Williams was sentenced as a second felony offender to 3½ to 7 years in prison.
Williams entered into a plea bargain which included a written waiver of his right to appeal, after consulting with counsel.
The trial court conducted a colloquy and obtained factual admissions from Williams before explaining the rights he was waiving.
On appeal, Williams challenged the validity of the appeal waiver, the search warrant’s sufficiency, the constitutionality of his conviction under the Second Amendment, and the sentence as excessive.

Issue	Williams' Argument	State's Argument	Held
Validity of appeal waiver	Waiver was not knowing/voluntary because court explained rights after factual admissions	Waiver was knowing/voluntary; Williams appreciated consequences	Valid waiver; record shows understanding and voluntariness
Suppression of evidence	Search warrant lacked probable cause/particularity	Warrants and application sufficient; probable cause existed	Waiver forecloses review; warrant supported by probable cause
Second Amendment challenge	Conviction violates Second Amendment post-Bruen	Challenge is waived, not properly raised, and lacks standing	Waived; not properly before court; no standing or merit
Excessive sentence	Sentence should be reduced as excessive	Sentence was appropriate and part of plea bargain	No reduction warranted; waiver bars review

People v. Bryant, 28 NY3d 1094 (NY Ct. App. 2016) (discusses valid waiver of right to appeal in plea context)
People v. Thomas, 34 NY3d 545 (NY Ct. App. 2019) (standards for evaluating knowing and voluntary appeal waivers)
People v. Seaberg, 74 NY2d 1 (NY Ct. App. 1989) (scope and effect of appeal waivers in guilty pleas)
Spinelli v. United States, 393 US 410 (US 1969) (probable cause requirements for warrants)
Aguilar v. Texas, 378 US 108 (US 1964) (standards for issuance of search warrants)