MARTIN v. PHILLIPS
422 P.3d 143
| Okla. | 2018Background
- Daniel Phillips pleaded (labeled on the form as an "Alford" plea) and was convicted of multiple counts of indecent or lewd acts with children under 16.
- The victims' mother sued Phillips for civil torts arising from the same acts and moved for partial summary adjudication on liability, relying on Phillips's criminal conviction.
- Phillips argued his Alford plea preserved his factual-denial and thus should not have preclusive effect in the civil case.
- The district court granted partial summary adjudication for the plaintiff; Phillips sought and obtained certification for immediate appellate review and petitioned this Court for certiorari.
- The Oklahoma Supreme Court considered (1) whether convictions based on pleas are entitled to collateral estoppel like jury verdict convictions, and (2) whether an Alford plea falls within Oklahoma's statutory exception for nolo contendere pleas.
- The Court affirmed the grant of partial summary adjudication and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a conviction based on a plea has preclusive (collateral estoppel) effect in a subsequent civil action | Plea-based convictions rest on a judge's finding of factual basis and thus preclude relitigation of guilt | Plea convictions are different from jury verdicts and should not automatically preclude civil liability | Plea convictions (if voluntary and intelligent) carry the same preclusive effect as verdicts because the court must find a factual basis before imposing sentence |
| Whether Oklahoma's nolo contendere statutory exception (§ 513) extends to Alford pleas | Section 513 only excepts nolo contendere pleas; other pleas may be used against defendant in civil suits | Alford pleas are like nolo contendere or otherwise preserve factual denial and should be excepted | § 513 does not mention Alford pleas; Legislature omitted them deliberately, so Alford pleas are not covered by the nolo contendere exception |
| Whether an Alford plea is legally a guilty plea (despite protestations of innocence) | Plaintiff: Alford is a guilty plea admitting legal guilt and thus preclusive | Phillips: An Alford plea is distinct (or akin to nolo contendere) because defendant maintains innocence; therefore it should not estop him in civil suit | An Alford plea is a form of guilty plea (a guilty plea entered while maintaining innocence); it has the preclusive effect of a guilty plea when voluntary and informed |
| Whether Phillips in fact admitted guilt on the plea form | Plaintiff: the plea form and judge's findings show a factual basis and admissions under penalty of perjury | Phillips: He entered an Alford plea and did not admit committing the acts | Record shows Phillips answered "yes" to committing the acts on the form, the judge found a factual basis, and Phillips did not claim coercion; court treated plea as guilty and preclusive |
Key Cases Cited
- North Carolina v. Alford, 400 U.S. 25 (1970) (establishes that a defendant may enter a constitutionally valid guilty plea while maintaining factual innocence if there is a strong factual basis)
- Lee v. Knight, 771 P.2d 1003 (Okla. 1989) (prior criminal conviction by jury has collateral estoppel effect in later civil actions)
- Haring v. Prosise, 462 U.S. 306 (1983) (discusses a guilty plea as an admission removing factual-guilt issue)
- McCarthy v. United States, 394 U.S. 459 (1969) (describes guilty plea as an admission of elements of the charge)