Justin R. Messersmith v. State of Indiana
2017 Ind. App. LEXIS 65
| Ind. Ct. App. | 2017Background
- On July 22, 2014, Justin R. Messersmith pushed his 4-year-old son against a trailer, injuring him; State charged Messersmith with Neglect of a Dependent (Level 5) and Battery on a Person <14 (Level 6).
- Messersmith and the State reached a plea agreement: Messersmith pleaded guilty to Count II (battery) and the State moved to dismiss Count I (neglect); the trial court accepted the plea and entered judgment on February 23, 2015.
- The State later moved to withdraw the plea agreement (March 30, 2015), asserting it had not conferred with the victim before entering the agreement; Messersmith objected.
- The trial court granted the State’s motion to withdraw the plea agreement; a jury trial followed in September 2015, and Messersmith was convicted on both counts.
- On appeal Messersmith argued the trial court abused its discretion by allowing the State to withdraw the plea after judgment had been entered; the Court of Appeals reversed and ordered entry of judgment and sentencing consistent with the original plea agreement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly allowed the State to withdraw a plea agreement after the court accepted the plea and entered judgment | State: Victim-rights requirements justified withdrawing the plea because the State failed to confer with the victim before agreeing to the plea | Messersmith: Once the court accepted the plea and entered judgment, due process required enforcement of the plea and barred unilateral withdrawal by the State | Court: Reversed — trial court abused discretion; defendant’s due process rights prevailed and the plea must be enforced |
Key Cases Cited
- Santobello v. New York, 404 U.S. 257 (1971) (when a plea rests on a prosecutor’s promise, the promise must be fulfilled)
- Puckett v. United States, 556 U.S. 129 (2009) (government is obligated to uphold its side of a valid plea bargain)
- Dunn v. State, 33 N.E.3d 1074 (Ind. Ct. App. 2015) (trial court discretion to revoke plea discussed; reversal where State invited error by affidavit claiming victim notice)
- Coker v. State, 499 N.E.2d 1135 (Ind. 1986) (entry of judgment after a guilty plea implicates constitutional rights)
- Lee v. State, 816 N.E.2d 35 (Ind. 2004) (contract principles guide plea-agreement analysis but do not control when due process protections apply)