Facts
Mr. Molina was offered a plea deal by the State, entailing a favorable State sentencing recommendation. Before the guilty plea was entered, however, the State withdrew their offer, claiming that the prosecutor was not authorized to make the proposed recommendation. Mr. Molina argued the district court should order enforcement of the plea deal, because he had “substantially relied on the agreement already,” and proceeding without the plea agreement would now be to his detriment. The district court agreed with Mr. Molina’s argument and ordered the enforcement of the original plea agreement. The State then filed an interlocutory appeal, which the Utah Court of Appeals granted for review.
Analysis
The Utah Court of Appeals’ review centers around the ruling of State v Francis, UT 2017, which stated that while generally the State may withdraw from a plea agreement at any time prior to the guilty plea being entered, the State may not withdraw when “a defendant has already reasonably and detrimentally relied” on the agreement. Such acts that indicate “detrimental reliance” may include providing information to the government, confessing guilt, or waiving certain procedural guarantees.
Mr. Molina claimed detrimental reliance in two ways: first, that he had admitted a key fact on the record by indicating his willingness to plead guilty to a lesser charge; and second, he had already called off witnesses set to appear at a forthcoming justification hearing. The Court of Appeals ruled that neither of these issues constituted detrimental reliance by Mr. Molin on the plea agreement previously offered by the State. The Court reasoned that merely indicating willingness to plead guilty to a lesser charge did not provide the State with any new material information about the case. Furthermore, willingness to plead does not automatically make a plea bargain enforceable.
Regarding Mr. Molina’s “calling off witnesses” claim, the Court of Appeals reasoned that nothing about the plea agreement itself or the State’s actions indicated this was something Mr. Molina should do. While the forthcoming justification hearing was rescheduled six months later, the Court stated this was again due to the district court’s busy calendar, and not a result of the retracted plea agreement.
Conclusion
The Court of Appeals concluded that the district court had erred in concluding Mr. Molina had detrimentally relied on the original plea agreement, and remanded the case for further proceedings.