Mabry v. Johnson
After respondent was convicted in an Arkansas state court on charges of burglary, assault, and murder, the Arkansas Supreme Court set aside the murder conviction, and plea negotiations ensued. A deputy prosecutor proposed to respondent's attorney that in exchange for a guilty plea to a charge of accessory after a felony murder, the prosecutor would recommend a 21-year sentence to be served concurrently with the concurrent burglary and assault sentences. However, when defense counsel called the prosecutor three days later and communicated respondent's acceptance of the offer, the prosecutor told counsel that a mistake had been made and withdrew the offer. He proposed instead that in exchange for a guilty plea he would recommend a 21-year sentence to be served consecutively to the other sentences. Respondent rejected the new offer, but after a mistrial was declared, he ultimately accepted the prosecutor's second offer, and the trial judge imposed a 21-year sentence to be served consecutively to the previous sentences. After exhausting state remedies, respondent sought habeas corpus relief in Federal District Court with respect to his guilty plea. The court dismissed the petition, holding that respondent had understood the consequences of his guilty plea, that he had received effective assistance of counsel, and that because it was not established that he had detrimentally relied on the prosecutor's first proposed plea agreement, respondent had no right to enforce it. However, the Court of Appeals reversed, holding that "fairness" precluded the prosecution's withdrawal of the plea proposal once accepted by respondent.
Held: Respondent's acceptance of the prosecutor's first proposed plea bargain did not create a constitutional right to have the bargain specifically enforced, and he may not successfully attack his subsequent guilty plea. Plea agreements are consistent with the requirements that guilty pleas be made voluntarily and intelligently. If a defendant was not fairly apprised of its consequences, his guilty plea can be challenged under the Due Process Clause. And when the prosecution breaches its promise with respect to an executed plea agreement, the defendant pleads guilty on a false premise, and hence his conviction cannot stand. However, [p505] respondent's plea was in no sense induced by the prosecutor's withdrawn offer, and it rested on no unfulfilled promise; he knew the prosecution would recommend a 21-year consecutive sentence. Thus, because it did not impair the voluntariness or intelligence of his guilty plea, respondent's inability to enforce the prosecutor's first offer is without constitutional significance. Neither is the question whether the prosecutor was negligent or otherwise culpable in first making and then withdrawing his offer relevant. Cf. Santobello v. New York, 404 U.S. 257. Pp. 507–511.
707 F.2d 323, reversed.
Stevens, J., delivered the opinion for a unanimous Court.
John Steven Clark, Attorney General of Arkansas, argued the cause for petitioner. With him on the briefs was Alice Ann Burns, Deputy Attorney General.
Jerrold J. Ganzfried argued the cause for the United States as amicus curiae urging reversal. On the brief were Solicitor General Lee, Assistant Attorney General Trott, Deputy Solicitor General Frey, and Gloria C. Phares.
Richard Quiggle, by appointment of the Court, 465 U.S. 1003, argued the cause and filed a brief for respondent.
This work is in the public domain in the United States because it is a work of the United States federal government (see 17 U.S.C. 105).
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