Michigan Supreme Court Holds Guilty Plea Cannot Be ‘Voluntary and Knowing’ When Induced by Inaccurate Understanding of Minimum and Maximum Prison Sentence
by David M. Reutter
The Supreme Court of Michigan held that a guilty plea cannot be understandingly or knowingly entered into when it was, in significant part, induced on the basis of an inaccurate understanding of the minimum and maximum possible prison sentence. It was error, therefore, to deny the defendant’s motion for postconviction relief.
Candace R. Guyton was charged with one count of armed robbery. In exchange for a plea of guilty, the prosecution agreed not to pursue charges in an unrelated case and to recommend a sentence within the guidelines minimum range of 51 to 85 months’ imprisonment. The prosecutor also agreed to dismiss a supplemental information charging Guyton as a third offense habitual offender.
For his role in the incident, co-defendant Kenneth Agnew, who had a prior armed robbery conviction, was sentenced pursuant to a plea agreement to 51 months to 80 years’ imprisonment for the armed robbery. The Kent County Circuit Court accepted Guyton’s plea and imposed a sentence at the top of the agreed upon guidelines range of 84 months to 60 years’ imprisonment.
In a postconviction motion, Guyton moved to withdraw her plea on grounds it was involuntary and unknowing because the prosecutor incorrectly classified her as a third-felony offender by double counting a single prior drug conviction. Neither the prosecutor nor the trial court corrected or informed Guyton of the error.
The trial court denied the motion, and Guyton timely appealed. The Court of Appeals noted that if a second offense habitual offender enhancement were applied, Guyton’s guidelines range would have a top end range of 106 months, and if a third offense habitual offender enhancement were applied, it would have increased to 127 months.
In affirming the trial court’s order, the Court of Appeals acknowledged that the plea deal only afforded Guyton a 21-month reduction from the top end as a second-offense offender rather than the 42-month reduction under the plea deal. However, the Court of Appeals reasoned that she “still obtained significant benefits as a result of the plea.” In affirming the trial court, the Court of Appeals concluded that there was substantial compliance with MCR 6.302 during the plea proceeding. The Michigan Supreme Court granted Guyton’s leave to appeal.
The Court began its analysis by observing that a guilty or no-contest plea serves to waive several constitutional rights but also triggers specific protections for the defendant. A plea must be “voluntary and knowing” under the Due Process Clause of the Fourteenth Amendment. People v. Cole, 817 N.W.2d 497 (Mich. 2012). The Court noted that its rules expressly incorporate these due process rights. MCR 6.302(A) (“The court may not accept a plea of guilty or nolo contendere unless it is convinced that the plea is understanding, voluntary, and accurate.”).
There must be substantial compliance with the requirements of MCR 6.302 for a valid plea. See People v. Saffold, 631 N.W.2d 320 (Mich. 2001). For a plea to be voluntary and knowing, the defendant “must be fully aware of the direct consequences of the plea,” and the penalty that will be imposed is the “most obvious direct consequence of a conviction.” Cole. Additionally, waivers of constitutional rights must be knowing and intelligent acts with “sufficient awareness of the relevant circumstances and likely consequences.” Brady v. United States, 397 U.S. 742 (1970).
The Court explained that because due process rights are implicated when waiving constitutional rights, trial courts may be required to advise defendants about certain facts not expressly required in MCR 6.302. People v. Blanton, 894 N.W.2d 613 (Mich. Ct. App. 2016). An accurate understanding of the habitual offender enhancement is undoubtedly a relevant circumstance, the Court stated. People v. Brown, 822 N.W.2d 208 (Mich. Ct. App. 2012). Similarly, a plea may not be knowing and voluntary if the defendant is misinformed about the benefits of the plea. See People v. Graves, 523 N.W.2d 876 (Mich. Ct. App. 1994). Consequently, the Court stated that the “focal inquiry in this particular case is thus not whether defendant received a benefit from the bargained plea agreement, but rather whether defendant was adequately informed and aware of the ‘relevant circumstances’ surrounding the entering of the plea and waiving of crucial constitutional rights.”
The Court concluded that Guyton’s waiver of her constitutional rights via her guilty plea was induced, in part, “by the prosecution’s and trial court’s assertions of an exaggerated benefit of the plea in lieu of proceeding to trial.” She was falsely led to believe that pleading guilty would result in the dismissal of a third offense enhancement, but she was never subject to it. This misinformation caused her to believe that her guilty plea was “insulating” her from “potentially 42 additional months” when in fact it was insulating her from potentially just an additional 21 months of imprisonment, the Court explained.
In turn, the misinformation rendered Guyton’s guilty plea involuntary because she lacked sufficient awareness of the relevant facts; that is, she “did not appreciate what she was truly avoiding by pleading guilty,” according to the Court. Thus, the Court ruled that her plea was not made “understandingly or voluntarily.”
One final issue the Court addressed was the prosecution’s argument that Guyton should have known her own criminal history and its effect on her habitual offender status. It rejected that argument because it’s the prosecution’s duty to ensure the defendant is provided with accurate and legally permissible notice when seeking an enhanced sentence. See MCL 769.13(1). The Court also noted that criminal records are often complicated, so the prosecution bears the “burden of properly notifying a defendant of their habitual offender status.”
Accordingly, the Court reversed Part III of the Court of Appeals’ opinion, vacated the remainder of the opinion, and remanded the case to the trial court to allow Guyton an opportunity to elect to allow her plea to stand or to withdraw it. See: People v. Guyton, 2023 Mich. LEXIS 1103 (2023).
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