People v. Cuadrado
The Supreme Court granted the defendant's motion under CPL 440.10, vacating an earlier conviction for first-degree assault, due to a perceived jurisdictionally defective waiver of indictment. The Appellate Division reversed this order, denying the defendant's motion and reinstating the original conviction and sentence. The majority held that CPL 440.10(2)(c) bars the defendant from raising an issue in a collateral attack that could have been reviewed on direct appeal, even if it concerns a jurisdictional defect. The court rejected the argument that applying this statutory bar in such a case would be unconstitutional. The dissenting opinion argued that the conviction was void ab initio because the waiver of indictment violated CPL 195.10(2)(b), asserting that such a fundamental jurisdictional defect cannot be procedurally waived.