The Court of Appeals in Maddux v. D.C, decided on July 25, 2019, considered whether the defendant should be allowed to withdraw his guilty plea to DUI after sentencing.
Before sentencing the burden on the defendant is “a fair and just reason” while after sentencing the burden elevated to “to correct manifest injustice, that is, justice demands withdrawal in the circumstances of the individual case.
Maddux’s central argument was that the Magistrate Judge pushed and coerced plea bargaining by threatening to detain him pending trial and pre-trial while making clear he would be treated as a first-time offender with a guilty plea and would be facing probation.
1) Claim of innocence:
The Court of Appeals held that the trial judge had not abused discretion in finding that defendant’s assertion of legal innocence based on a sleep apnea defense provided no support to his manifest injustice claim and was quite weak.
Blaming the car accident to fatigue caused by sleep apnea was unconvincing and unpersuasive because:
- An empty bottle of vodka was found in the car;
- Defendant was confused and disoriented after the accident consistent with inebriation;
- There were multiple signs of impairment, failure of field sobriety tests, and refusal to submit to breathalyzer.
2) Rule 11 Violation:
Judicial Officer violates Rule 11 if acts coercively or goes beyond a neutral inquiry and encourages accepting of a guilty plea or even if suggests that the sentence will be more lenient or harsh depending on whether the plead is entered or trial path selected.
Here the trial court did not violate Rule 11. The court addressed the defendant personally and in open court and determined via colloquy if the plea was voluntary and did not result from force, threats, or promises.
The judge probed and inquired sufficiently:
- Whether he was certain he wanted to plead guilty;
- Whether he had any questions or concerns;
- Whether he was clear of mind and not under the influence of any drugs;
- Whether he had adequately consulted with his attorney, whether he needed more time;
- Whether he clearly understood the rights he was relinquishing and the terms of his plea agreement, and
- Whether he agreed with the prosecutor’s proffer and admitted his guilt.
3) Guilty plea to avoid jail:
The pre-trial detention was justified thus pleading guilty to avoid detention was not unlawful. Maddux had a hard choice between two unpalatable alternatives – both lawful though – pleading guilty and probation or being detained pending trial. Pressure created by lawful detention is inherent in plea bargaining and not atypical and does reach to the level of coercion that would render a plea involuntary.
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