## Facts

- Juan Rodriguez was robbed at gunpoint by three individuals, including Sylvester Jones, as Rodriguez entered his car on January 5, 1975.
- The assailants forced Rodriguez into his vehicle, drove some distance, took his wallet, and released him.
- Jones was indicted for first- and second-degree robbery, third-degree grand larceny, and fourth-degree criminal weapon possession.
- After repeated adjournments tied in part to difficulty locating Rodriguez, the prosecution announced readiness for trial on February 3, 1976.
- Plea negotiations continued, and on April 26, 1976, Jones pleaded guilty to third-degree robbery in full satisfaction of the indictment after admitting facts establishing the offense.
- The District Attorney’s office received notice on April 22, 1976—four days before the plea—that Rodriguez had died, but did not disclose that fact to the defense or the court before the plea was entered and accepted.

## Issues

1. Whether due process was violated when the prosecution did not disclose, during plea negotiations and the plea colloquy, that it had learned the complaining witness died before the guilty plea.
2. Whether that nondisclosure required allowing the defendant to withdraw an otherwise facially valid guilty plea.

## Decision

- The New York Court of Appeals affirmed the conviction.
- The court held that nondisclosure of the complainant’s death before the plea did not deny due process and did not render the plea unknowing, unintelligent, or involuntary.
- The court upheld denial of the motion to withdraw the plea, concluding the defendant was not entitled to withdraw merely because later information showed his assessment of the prosecution’s case was mistaken.

## Legal Principles

- A guilty plea is not invalid solely because the defendant later learns information that would have affected bargaining position or trial-risk assessment, where the plea was otherwise knowing, intelligent, and voluntary.
- Prosecutorial nondisclosure, in the plea setting, of information affecting only the perceived strength or trial presentation of the prosecution’s case—rather than factual guilt—does not, without more, establish a due process violation.
- A trial court may deny plea withdrawal absent proof that the plea was induced by fraud, coercion, or a material mistake bearing on the defendant’s understanding of guilt, the charge, or the rights waived.

## Conclusion

The court sustained Jones’s guilty plea because the undisclosed death of the complaining witness related to trial-proof considerations rather than the truth of Jones’s sworn admission of guilt, and the plea remained voluntary, knowing, and intelligent despite the post-plea revelation.


People v. Jones, 44 N.Y.2d 76, 375 N.E.2d 41 (N.Y. 1978)