The Minnesota DWI case of the week is the Minnesota Court of Appeals decision set forth in Melde v. State of Minnesota.
Mr. Melde was charged with two counts of Felony DWI and one count of Driving After Cancellation. He agreed to plead guilty to one count of Felony DWI and to Driving After Cancellation when the prosecutor agreed to recommend that the execution of the sentence be "stayed" (i.e. the prosecutor agreed that Mr. Melde would not be required to go to prison).
The district court judge accepted the guilty plea and adjudicated Mr. Melde guilty. The parties and the district court agreed that there would be a pre-sentence investigation and that the court would sentence Mr. Melde after reviewing the pre-sentence report.
After the pre-sentence report was prepared and reviewed by the district court, the judge decided not to accept the plea agreement. The district court offered Mr. Melde the opportunity to withdraw his guilty plea but told the defendant that it would sentence him to 46 months (i.e. at the bottom of the sentencing guidelines) if he affirmed his guilty plea.
Mr. Melde decided not to withdraw his guilty plea and was sentenced, as promised, to 46 months in prison. Mr. Melde subsequently brought a Petition for Post-Conviction Relief asserting that the district court impermissibly injected itself into the plea negotiations by promising a particular sentence.
The Minnesota Court of Appeals agreed with Mr. Melde and reversed his conviction. The Court of Appeals noted that, "The district court has a role to play in plea negotiations, but it may not usurp the responsibility of counsel or become excessively involved in plea negotiations. It is improper for a district court to offer the defendant an anticipated sentencing result that is not a part of an existing agreement between the defendant and the prosecutor."
"The district court's proper role is one of discreet inquiry into the propriety of the settlement submitted for judicial acceptance, both to make certain that an innocent person has not been induced to plead guilty to a crime and to protect society from a defendant being permitted to bargain for an excessively lenient sentence. If the district court finds the terms of the a plea agreement to be unacceptable, it must simply reject the agreement."
When a district court rejects a plea agreement, the defendant is automatically entitled to withdraw his plea if one has been entered. Here the district court properly informed Mr. Melde of his right to withdraw his guilty plea. However, the court also told Mr. Melde that it would impose a 46-month sentence if he affirmed his guilty plea. "By promising a particular sentence that was not part of an agreement between the prosecutor and the defendant, the district court improperly injected itself into plea negotiations. Therefore Melde's guilty plea was per se invalid."
My only criticism of the result is that sometimes an active role by the court facilitates a proper resolution of the case. There are times when one encounters an over-zealous prosecutor who demands a sentence far in excess of anything warranted by the offense. If the court takes an active role and indicates it is not going to go along with the prosecutor's demands, the court's involvement can go a long way in avoiding an unnecessary trial.
F.T. Sessoms, Minnesota DWI Lawyer
F.T. Sessoms, Minnesota DWI Lawyer
