People v. Steinagle
Docket 139 KA 24-01249
Court of record · Indexed in NoticeRegistry archive · AI-enriched for research
- Filed
- Jurisdiction
- New York
- Court
- Appellate Division of the Supreme Court of the State of New York
- Type
- Opinion
- Case type
- Criminal Appeal
- Disposition
- Affirmed
- Citation
- 2026 NY Slip Op 02515
- Docket
- 139 KA 24-01249
Appeal from a judgment of conviction following a guilty plea to kidnapping in the second degree in Supreme Court, Erie County.
Summary
The Appellate Division, Fourth Department affirmed a June 25, 2024 judgment convicting Carol Steinagle after she pleaded guilty to second-degree kidnapping (Penal Law § 135.20). The defendant argued on appeal that her plea was not knowing and voluntary and that her sentence was harsh. The court found the claim unpreserved because she did not move to withdraw the plea or vacate the judgment, declined to review it in the interest of justice, and rejected the claim that the sentence was unduly harsh, so the conviction and sentence were affirmed.
Issues Decided
- Whether defendant's guilty plea was entered knowingly and voluntarily.
- Whether the sentence imposed was unduly harsh or severe.
Court's Reasoning
The court held the voluntariness claim was not preserved because defendant did not move to withdraw her plea or vacate the judgment, which is the proper procedural mechanism to challenge a plea. The court also declined to exercise its discretionary authority to review the claim in the interest of justice. On the sentence claim, the court concluded the term imposed was not unduly harsh.
Authorities Cited
- Penal Law § 135.20
- People v Council234 AD3d 1361 (4th Dept 2025)
- People v Cunningham213 AD3d 1270 (4th Dept 2023), lv denied 39 NY3d 1110 (2023)
- CPL 470.15(3)
Parties
- Appellant
- Carol Steinagle
- Respondent
- The People of the State of New York
- Judge
- Deborah A. Haendiges
- Attorney
- Lyle T. Hajdu
- Attorney
- Tabitha R. Salonen
- Attorney
- Michael J. Keane
Key Dates
- Decision date
- 2026-04-24
- Judgment rendered
- 2024-06-25
What You Should Do Next
- 1
Consider motion to vacate plea (if timely)
Consult defense counsel immediately about whether a postjudgment motion to vacate the plea or withdraw it remains available under CPL procedures and whether any new grounds exist to support such a motion.
- 2
Evaluate leave to appeal to Court of Appeals
Assess the viability and timeliness of applying for leave to appeal to the New York Court of Appeals and prepare supporting briefs if appropriate.
- 3
Review sentence and collateral options
Discuss with counsel whether any collateral relief (such as resentencing motions, clemency, or postconviction relief) is available given the affirmed judgment.
Frequently Asked Questions
- What did the court decide?
- The appellate court affirmed the conviction and sentence of Carol Steinagle after finding her challenge to the plea unpreserved and concluding the sentence was not unduly harsh.
- Who is affected by this decision?
- The decision directly affects defendant Carol Steinagle and upholds the conviction and sentence imposed by the trial court.
- Why didn't the court review the claim the plea was involuntary?
- Because defendant did not file the required motion to withdraw the plea or vacate the judgment, the claim was not preserved for appeal and the court declined to review it in the interest of justice.
- Can this decision be appealed further?
- A further appeal to the Court of Appeals would require permission; the decision does not describe any pending leave application, so seeking leave to appeal would be the next procedural step if timely and appropriate.
The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.
Full Filing Text
People v Steinagle - 2026 NY Slip Op 02515 People v Steinagle 2026 NY Slip Op 02515 April 24, 2026 Appellate Division, Fourth Department THE PEOPLE OF THE STATE OF NEW YORK, RESPONDENT, v CAROL STEINAGLE, DEFENDANT-APPELLANT. Supreme Court of the State of New York, Appellate Division, Fourth Judicial Department Decided on April 24, 2026 139 KA 24-01249 Present: Whalen, P.J., Lindley, Curran, Smith, And Delconte, JJ. ERICKSON WEBB SCOLTON & HAJDU, LAKEWOOD (LYLE T. HAJDU OF COUNSEL), FOR DEFENDANT-APPELLANT. MICHAEL J. KEANE, DISTRICT ATTORNEY, BUFFALO (TABITHA R. SALONEN OF COUNSEL), FOR RESPONDENT. Appeal from a judgment of the Supreme Court, Erie County (Deborah A. Haendiges, J.), rendered June 25, 2024. The judgment convicted defendant upon her plea of guilty of kidnapping in the second degree. It is hereby ORDERED that the judgment so appealed from is unanimously affirmed. Memorandum: Defendant appeals from a judgment convicting her upon her plea of guilty of kidnapping in the second degree (Penal Law § 135.20). We affirm. Defendant failed to preserve for our review her contention that her plea was not knowingly and voluntarily entered inasmuch as she did not move to withdraw the plea or to vacate the judgment of conviction ( see People v Council , 234 AD3d 1361, 1362 [4th Dept 2025]; People v Cunningham , 213 AD3d 1270, 1271 [4th Dept 2023], lv denied 39 NY3d 1110 [2023]), and we decline to exercise our power to review the contention as a matter of discretion in the interest of justice ( see CPL 470.15 [3] [c]; Council , 234 AD3d at 1363). Contrary to defendant's contention, her sentence is not unduly harsh or severe. Entered: April 24, 2026 Ann Dillon Flynn