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Supreme Court refuses to enforce original plea bargain based on contract principles

[JURIST] The US Supreme Court [official website] on Monday overturned [opinion, PDF] a lower court's decision to enforce an original plea bargain in accordance with contract law principles, finding such application was not supported by federal law.

The case arose from a California criminal conviction. Respondent Michael Cuero was charged with a misdemeanor and two felonies, one of which was deemed a "strike" under California's "three-strike" law. Cuero pleaded guilty to the two felonies, which yielded a maximum sentence of 14 years in prison, a $10,000 fine and four years on parole. After accepting the plea deal and before sentencing, the state became aware of Cuero's previous four imprisonments, two of which were also "strikes" under California law and would raise Cuero's sentencing minimum to 25 years imprisonment.

The trial court permitted the state to amend its complaint and Cuero to withdraw his guilty plea under California law, which permits the state to amend the pending complaint when prior felony charges are not included in the guilty plea. The trial court distinguished this amendment from one which adds new charges, finding it did not "fundamentally alter the substance of the complaint." Cuero was subsequently convicted and sentenced to 25 years to life in prison.

Cuero filed a federal habeas petition, and the US Court of Appeals for the Ninth Circuit [official website] reversed the trial court's decision, finding that specific performance of the original plea deal was "necessary to maintain the integrity and fairness of the criminal justice system." Specifically, the court found "specific performance" was of the original plea bargain was the proper remedy in this case where previous court decisions treated withdraw of an agreed-upon plea bargain as a breach of contract.

On appeal, the Supreme Court considered whether the trial court's decision "involved an unreasonable application of clearly established federal law," as required under the Antiterrorism and Effective Death Penalty Act of 1996 [text] to uphold the Ninth Circuit's reversal. The Supreme Court overturned the Ninth Circuit's decision, finding Supreme Court precedent did not interpret federal law as to require specific performance in situations as this. Under these circumstances, the Ninth Circuit should not have overturned the trial court's decision: "[w]here, as here, none of our prior decisions clearly entitles Cuero to the relief he seeks, the state court's decision could not be contrary to any holding from this Court.'"

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