People v. Achaibar

In order for a guilty plea to be entered knowingly, intelligently and voluntarily, a defendant must be advised of the direct consequences of the plea (People v Ford, 86 NY2d 397, 403 [1995]). Although there is no mandatory catechism, a minimum requirement for a valid plea is that the defendant understands the direct penal consequences (see People v Catu, 4 NY3d 242 [2005]).

*390Here, the plea minutes show only that prior to the allocution the prosecutor, defense attorney and court all agreed the disposition was an “open D,” that the prosecutor intended to make an unspecified recommendation at…