Cuffley v. State
416 Md. 568
| Md. | 2010Background
- Petitioner pleaded guilty to one count of robbery under a binding plea agreement in Harford County (Oct. 23, 2002).
- Terms: State would recommend a sentence within the guidelines (four to eight years) with disposition deferred pending a probation violation.
- Court stated the plea would be within the guidelines and that probation conditions were within the court's discretion.
- Sentencing hearing resulted in a 15-year sentence, with all but six years suspended, consecutive to a separate probation-violation sentence; five-year probation followed release.
- Petitionermovant filed a Rule 4-345(a) motion to correct an illegal sentence, arguing the sentence exceeded the plea agreement.
- Court denied the motion; Court of Special Appeals affirmed; Maryland Court of Appeals granted certiorari to address whether the sentence violated the binding plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a sentence exceeding the guidelines but suspended beyond them violates a binding plea | Cuffley | State | Sentence violated the plea; requires re-sentencing consistent with the agreement |
| Proper interpretation of Rule 4-243 regarding plea terms and record reliance | Cuffley | State | Rule 4-243 requires record-based, strict compliance; extrinsic evidence limited in defining terms |
| Whether extrinsic evidence may be used to interpret the defendant's reasonable understanding | Cuffley | State | Ambiguities resolved in defendant's favor; extrinsic evidence may be considered when appropriate |
| Whether incorporation by reference and the meaning of 'within the guidelines' imported the Guidelines to include non-suspended time | Cuffley | State | Incorporation by reference fixes non-suspended time; probationary period is governed by the negotiated terms |
| Appropriate remedy when a plea agreement is breached | Cuffley | State | Remedies include specific enforcement or withdrawal of the plea; court may remand for re-sentencing |
Key Cases Cited
- Santobello v. New York, 404 U.S. 257 (U.S. 1971) (promises at plea must be fulfilled)
- Brockman v. State, 277 Md. 687 (Md. 1976) (plea bargains should be encouraged and enforced fairly)
- Tweedy v. State, 380 Md. 475 (Md. 2004) (interpret plea terms by the defendant's reasonable understanding)
- Solorzano v. State, 397 Md. 661 (Md. 2007) (apply reasonable understanding when interpreting plea terms, with ambiguity resolved in defendant's favor)
- Poole v. State, 321 Md. 482 (Md. 1991) (principle of fair play and equity in plea proceedings)
- Wright v. Commercial & Sav. Bank, 297 Md. 148 (Md. 1983) (contract interpretation includes incorporation by reference)
- United States v. Harvey, 791 F.2d 294 (4th Cir. 1986) (extrinsic evidence may govern plea interpretation in appropriate cases)
- Solorzano v. State (footnote discussed in context), 397 Md. 661 (Md. 2007) (solicits clear on-record explanation when relying on guidelines)