New York Law Watch
CPL 30.30 (6): speedy-trial claims after a guilty plea
Updated October 29, 2026 · 3 decisions
The Court of Appeals addressed CPL 30.30 (6) in Ekukpe and Nantan on October 29, 2026. The decisions below concern the waiver of appellate review of a speedy-trial claim and the application of that provision to pending appeals. Liles addresses the separate ninety-day custody clock under CPL 30.30 (2) (a). Each entry links to the official text and the Law Watch record.
Edited by Eric McAvey.
The decisions
People v Nantan
Court of Appeals · October 29, 2026
Law Watch record: 2026 NY Slip Op 06379
Holding CPL 30.30 (6) unambiguously expands appellate review of speedy trial claims to all cases, including those arising from guilty pleas entered before the statute’s effective date. The provision applies to appeals pending when it took effect because it is a procedural and remedial statute that mandates review without reservation.
CPL 30.30 (6) unambiguously and unconditionally applies to all criminal appeals challenging an underlying order finally denying a motion to dismiss based on speedy trial grounds
2026 NY Slip Op 06379, at the official text
People v Ekukpe
Court of Appeals · October 29, 2026
Law Watch record: 2026 NY Slip Op 06378
Holding CPL 30.30 (6) does not preclude a criminal defendant from waiving the right to appeal a statutory speedy trial claim as part of a negotiated plea bargain. The statute’s plain text only abrogates the rule that a guilty plea forfeits such claims, but it does not address or prohibit appeal waivers.
CPL 30.30 (6) does not shield statutory speedy trial claims from appeal waivers
2026 NY Slip Op 06378, at the official text
People ex rel. Liles v Richards
Appellate Division, Second Department · September 2, 2026
Law Watch record: 2026 NY Slip Op 05191
Holding The court held that the 90-day readiness clock under CPL 30.30(2)(a) only includes the actual periods of time a defendant spends in custody, excluding any time spent out on bail. Consequently, the defendant was not entitled to release because the total time chargeable to the People was less than 90 days.
we hold that the calculable time within which the People must be ready for trial under CPL 30.30(2)(a) is only the actual period or periods of time that the defendant spent incarcerated
2026 NY Slip Op 05191, at the official text
Statute
CPL 30.30 (6); CPL 30.30 (2) (a).
Published October 29, 2026. Updated October 29, 2026.