Commonwealth, Aplt. v. Martinez, G.
30 MAP 2015
| Pa. | Sep 28, 2016Background
- Three consolidated cases (Shower, Martinez, Grace) involved plea agreements accepted under Megan’s Law; later enactment of SORNA increased or added sex-offender registration obligations.
- Shower and Martinez pleaded to indecent assault; under Megan’s Law each faced 10 years of registration but SORNA reclassified the offenses as Tier III (lifetime) triggering lifetime registration.
- Grace pleaded to offenses that under Megan’s Law did not require registration; SORNA would classify his offense as Tier II, requiring 25 years of registration.
- Each defendant petitioned the trial court to specifically enforce the plea bargain term reflected at sentencing (i.e., the registration expectation under Megan’s Law), arguing the Commonwealth must honor plea terms.
- Trial court granted relief (specific performance); the Superior Court, relying on its en banc decision in Commonwealth v. Hainesworth, affirmed that accepted plea agreements that included non‑registration or limited registration terms must be enforced despite SORNA.
- The Supreme Court of Pennsylvania affirmed, holding that plea agreements are contractual in nature and, when a registration term was part of the plea accepted by the court, the defendant is entitled to specific performance of that term.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the plea agreements included enforceable terms limiting or avoiding sex‑offender registration | Appellees: the pleas (and plea colloquy/stipulations) expressly or implicitly limited registration under Megan’s Law | Commonwealth: registration requirements under new statute (SORNA) govern; registration is a collateral consequence not a contractual term | Held: plea record and stipulations show registration terms were part of the bargains; those terms are enforceable |
| Whether specific performance is an available remedy to enforce plea‑agreement terms | Appellees: specific performance is appropriate because pleas are contractual and defendants gave up trial rights in reliance on promises | Commonwealth: legislative change to collateral consequences alters the legal landscape, so enforcement should yield to statute | Held: specific performance is an appropriate contract remedy when a court accepted the plea and the term was part of the agreement |
| Whether SORNA’s registration requirements are merely collateral consequences that negate enforcement of plea terms | Commonwealth: registration is a non‑punitive collateral consequence and legislature can change it post‑plea | Appellees: whether collateral or punitive is irrelevant—if registration was a bargained term, it must be enforced | Held: court decides cases on contract principles; collateral‑consequence characterization does not defeat enforcement of an express plea term |
| Whether the Commonwealth may invoke constitutional Contract Clause or other defenses to avoid specific performance | Commonwealth: subsequent legislation (SORNA) alters obligations; Contract Clause claims invoked defensively | Appellees: trial courts adjudicated under contract law; Contract Clause not basis of lower courts’ rulings | Held: Court resolves disputes on common‑law contract grounds (not Contract Clause); statutes enacted later do not erase an enforceable plea term accepted by the court |
Key Cases Cited
- Santobello v. New York, 404 U.S. 257 (1971) (when plea rests on prosecutorial promise, that promise must be fulfilled)
- Puckett v. United States, 556 U.S. 129 (2009) (plea bargains are essentially contracts)
- Commonwealth v. Zuber, 353 A.2d 441 (Pa. 1976) (defendant entitled to benefit of plea bargain even where original sentence terms are legally impermissible; courts may fashion relief to give bargained benefit)
- Commonwealth v. Spence, 627 A.2d 1176 (Pa. 1993) (after a plea is accepted by the court, the Commonwealth must abide by the terms of the plea)
- Commonwealth v. Hainesworth, 82 A.3d 444 (Pa. Super. 2013) (en banc) (accepted plea agreements that contemplate non‑registration or limited registration must be specifically enforced against the Commonwealth)