Baines v. State
416 Md. 604
| Md. | 2010Background
- Baines was charged on a 30-count indictment in Prince George's County related to a home invasion; he pleaded guilty to two armed-robbery counts under a plea agreement to be sentenced within the Guidelines.
- The overall Maryland guidelines range for the two armed-robbery offenses was 7 to 13 years; the plea hearing confirmed the court would sentence within the Guidelines.
- Sentencing imposed 20 years on count 1 with 7 years suspended, and 20 years on count 8 with 6 years suspended, consecutive, each with 5 years probation.
- Petitioner argued the total sentence (including suspended time) exceeded the binding guideline limit, breaching the plea; he sought specific performance.
- Court of Special Appeals and then the Court of Appeals addressed whether the sentence breached the plea and remanded; the majority relied on Cuffley to hold breach.
- The plea record showed no explicit on-record statement that probation could be imposed or that suspended time could push beyond the guidelines; extrinsic evidence was evaluated per Cuffley.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the sentence breach the plea by exceeding guidelines with suspended time? | Baines argues total sentence exceeded the cap in the plea. | State contends Paired execution within guidelines; suspended time may extend beyond guidelines. | Yes; breach; remand for specific performance. |
| What controls the reasonable understanding of a plea term: record-only or extrinsic evidence? | Extrinsic evidence can clarify defendant’s understanding. | Plea terms are determined by the record at plea; extrinsic evidence is limited. | Cuffley controls; record governs unless ambiguity resolved in defendant’s favor. |
| Is specific performance the proper remedy for breach of a plea agreement? | Petitioner seeks specific performance of the bargain. | Remedies may vary; execution should conform to the plea. | Yes; grant specific performance and remand for re-sentencing consistent with the opinion. |
Key Cases Cited
- Cuffley v. State, 416 Md. 568 (2010) (establishes that a court cannot consider extrinsic evidence to define plea terms; breach when total sentence exceeds negotiated term)
- Solorzano v. State, 397 Md. 661 (2007) (ambiguous plea terms resolved against the State; incorporation of guidelines must be clear on record)
- Daley v. State, 61 Md. App. 486 (1985) (warning on informing defendants of direct consequences of pleading guilty)
- Moore v. United States, 592 F.2d 753 (4th Cir. 1979) (necessity of informing defendants about maximum penalties to satisfy Rule 11-like rights)
- United States v. Harvey, 791 F.2d 294 (4th Cir. 1986) (extrinsic evidence may be used to determine mutual assent in some plea ambiguities)