The People of the State of New York v. Charles Angelo Spitaleri

Summary

The New York Court of Appeals reversed the defendant's heroin possession conviction, holding that a guilty plea withdrawn by the court cannot be introduced as evidence of guilt in the prosecution's direct case. The court relied on the U.S. Supreme Court's decision in Kercheval and distinguished earlier New York precedent, concluding that a withdrawn plea is "out of the case forever". The opinion also noted, without deciding, the issue of whether the defendant waived attorney‑client privilege by testifying about his lawyer.