Guilty Plea Waives All Nonjurisdictional Pre-Trial and Trial Defects.

Defendant went to trial before he pled guilty.  On appeal he argued the court erred in admitting recorded conversations. The Fourth Department determined, by pleading guilty, the defendant forfeited his right to seek review of any nonjurisdictional defects in the proceedings, including issues arising from an audibility hearing and evidentiary rulings during trial.  People vs Alvarado, 130, KA 11-02011 Fourth Dept. 2-1-13