317 P.3d 49
Idaho Ct. App.2013Background
- McAmis was charged with grand theft and subject to a potential persistent violator enhancement.
- Plea agreement: State would dismiss the enhancement and recommend a five-year unified sentence with two years determinate suspended to probation.
- State did not follow the recommendation; prosecutor recommended incarceration.
- Trial court imposed an 11-year unified sentence with five years determinate, running concurrent with another case.
- McAmis appealed; post-conviction relief was granted by the district court, which ordered specific performance instead of allowing withdrawal of the guilty plea.
- McAmis appeals the remedy selection as an abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Remedy for plea breach: withdrawal vs specific performance | McAmis seeks withdrawal of plea | District court chose specific performance to retain bargain | Remedy within courts’ discretion; both viable depending on factors |
| Is specific performance appropriate given Mabry/Puckett framework? | Breach supports withdrawal; Mabry controls | Puckett abrogates Mabry; specific performance allowed | District court properly applied framework and discretionary choice within law |
Key Cases Cited
- Santobello v. New York, 404 U.S. 257 (1971) (plea breach requires remedy to protect rights)
- Mabry v. Johnson, 467 U.S. 504 (1984) (breach can render plea voidable; remedy available)
- Puckett v. United States, 556 U.S. 129 (2009) (breach not retroactively invalidates plea; remedy available)
- State v. Stocks, 153 Idaho 171, 280 P.3d 198 (Ct. App. 2012) (remedies for plea breach; specific performance favored in some contexts)
- State v. Jones, 139 Idaho 299, 77 P.3d 988 (Ct. App. 2003) (remedy discretion in breach scenarios)
- State v. Seaman, 125 Idaho 955, 877 P.2d 926 (Ct. App. 1994) (consideration of remedies for plea breaches)
- State v. Rutherford, 107 Idaho 910, 693 P.2d 1112 (Ct. App. 1985) (equitable factors in choosing remedy)
- State v. Pierce, 150 Idaho 725, 249 P.3d 1180 ( Ct. App. 2011) (recognition of Mabry and Puckett reconciliations)
- Lafler v. Cooper, 132 S. Ct. 1376 (2012) (remedy must neutralize taint without windfall)
- Puckett v. United States, 556 U.S. 129 (2009) (abrogates Mabry’s retroactivity view on plea validity)
- Morrison v. United States, 449 U.S. 361 (1981) (remedy considerations balance fairness and deterrence)