Kami Lizarraga, an Office of the Appellate Defender staff attorney who represented Patillo, said Thursday that her office was “thrilled that the First Department recognized today that due process requires ‘a more probing inquiry’ in the plea colloquies of those who are intellectually disabled.”

“A wealth of evidence before the trial court demonstrated Darrell’s extremely low IQ and his diminished abilities to comprehend and reason,” she said by email, “yet nothing about the plea allocution considered how Darrell’s intellectual disability interplayed with the allegations against him or whether he even understood the plea process.”