People of the State of New York v. Joseph Medina-Hidalgo
Attorneys and Parties
Brief Summary
Criminal law—sentencing financial obligations (mandatory surcharge and related fees).
The Supreme Court, New York County, accepted defendant’s guilty plea to criminal possession of a controlled substance in the second degree, sentenced him to three years’ imprisonment, and imposed a mandatory surcharge and fees.
The mandatory surcharge and fees imposed at sentencing were vacated; the conviction and custodial sentence were otherwise affirmed.
Exercising its interest-of-justice authority and relying on People v. Chirinos, 190 AD3d 434 (1st Dept 2021), and noting the People did not oppose, the court vacated the surcharge and fees.
Background
Defendant pleaded guilty in Supreme Court, New York County, to criminal possession of a controlled substance in the second degree. The court sentenced him to a three-year term of imprisonment and imposed the mandatory surcharge and related fees. Defendant appealed, seeking relief from the financial obligations imposed at sentencing.
Lower Court Decision
Judgment rendered November 15, 2019, convicting defendant on his guilty plea and imposing a three-year sentence along with a mandatory surcharge and fees.
Appellate Division Reversal
The Appellate Division unanimously modified the judgment by vacating the surcharge and fees under its interest-of-justice powers, citing People v. Chirinos, and otherwise affirmed the conviction and sentence.
Legal Significance
Confirms the Appellate Division, First Department’s practice of using its interest-of-justice discretion to relieve defendants of mandatory surcharges and fees on appeal, consistent with People v. Chirinos, particularly where the People do not oppose such relief.
On appeal, New York courts may vacate mandatory surcharges and fees in the interest of justice—without disturbing the conviction or prison term—especially where the prosecution does not oppose.