AI Generated Opinion Summaries

Decision Information

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

  • The Defendant pleaded guilty to several charges, including receiving or transferring a stolen vehicle, receiving stolen property, larceny, and escape or attempt to escape from jail, as part of a joint plea and disposition agreement (para 1).

Procedural History

  • Appeal from the District Court of San Juan County, Thomas J. Hynes, District Judge, April 9, 2013.

Parties' Submissions

  • Appellant: Contended that the failure to afford extradition due process resulted in an improper search and seizure and that he was not advised of the dangers of representing himself nor afforded reasonable access to resources to prepare his defense (para 1).
  • Appellee: Argued in favor of affirming the conviction, suggesting that the Defendant's guilty plea constituted a waiver of the right to appeal on grounds other than jurisdictional issues (para 2).

Legal Issues

  • Whether the Defendant's guilty plea waived his right to appeal his conviction on grounds other than jurisdictional issues.
  • Whether the Defendant's claims of improper extradition process and lack of resources to prepare his defense are jurisdictional issues that can be raised post-guilty plea.

Disposition

  • The Court of Appeals affirmed the decision of the lower court (para 4).

Reasons

  • Per Jonathan B. Sutin, with Roderick T. Kennedy, Chief Judge, and James J. Wechsler, Judge, concurring:
    The Court held that a voluntary guilty plea generally waives the defendant's right to appeal his conviction on grounds other than jurisdictional issues. Since the Defendant's plea agreement did not reserve any issues for appeal, he was limited to raising jurisdictional issues. The Court concluded that the Defendant's claims regarding the extradition process and lack of resources were not jurisdictional and were therefore waived by his guilty plea (paras 2-3).
    The Defendant's memorandum in opposition did not address the Court's proposed summary affirmance on the basis that he was limited to raising jurisdictional issues, and the arguments raised were not jurisdictional. Consequently, for the reasons stated in the Court's notice of proposed disposition, the appeal was affirmed (para 3).
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