The People of the State of New York v. John N. Rowland

Summary

The New York Court of Appeals reversed the Appellate Division, granting the defendant’s motion to vacate his Alford plea and sentence because the promise of concurrent sentencing was a material inducement that could not be fulfilled after the prior conviction was reduced, and remanded the case for further proceedings. Justice Graffeo dissented, arguing that the majority’s rule should not apply when the concurrent sentence adds additional time.