Miguel Camacho v. State of Rhode Island
58 A.3d 182
R.I.2013Background
- Camacho indicted Nov. 30, 1989 on two counts of second-degree child molestation.
- He was found guilty Jan. 15, 1991, sentenced to 12 years (6 to serve, 6 suspended) with probation.
- On remand for new trial after a vouched witness-tampering concern, Camacho entered an Alford plea on June 4, 1993.
- July 23, 2010 Camacho filed postconviction-relief seeking to vacate the plea and sentence.
- Superior Court denied relief Aug. 3, 2011; Camacho timely appealed Aug. 22, 2010; Rhode Island Supreme Court affirmed.
- Court held the plea was voluntary, intelligent, and knowingly made under Rule 11 and totality of circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the Alford plea colloquy valid under Rule 11? | Camacho argues elements/charges were omitted. | State asserts total record shows understanding. | Plea valid; no relief warranted. |
| Did omission of two elements undermine the plea's validity? | Missing elements undermine knowing waiver. | Omissions harmless under totality. | Omissions harmless; plea upheld. |
| Was there a sufficient factual basis for the plea? | Record lacks explicit basis for elements. | Prosecutor's recital supplied the basis. | Yes, sufficient factual basis existed. |
| Did the postconviction relief court apply the correct standard? | Standard misapplied, review insufficient. | Proper totality-of-the-circumstances analysis used. | Correct standard applied; relief denied. |
Key Cases Cited
- State v. Feng, 421 A.2d 1269 (R.I. 1980) (establishes need for factual basis or record-based understanding in plea)
- State v. Frazar, 822 A.2d 931 (R.I. 2003) (flexible inquiry into knowing plea; not require element-by-element recitation)
- State v. Williams, 404 A.2d 814 (R.I. 1979) (judge must ensure defendant understands charge and consequences)
- Tavares v. State, 826 A.2d 941 (R.I. 2003) (proper colloquy when rights explained and understood)
- Azevedo v. State, 945 A.2d 335 (R.I. 2008) (uses record, testimony, and plea transcripts to assess knowing waiver)
- Higham v. State, 45 A.3d 1180 (R.I. 2012) (deference to factual findings; de novo review for constitutional issues)
- Hassett v. State, 899 A.2d 430 (R.I. 2006) (constitutional rights review in postconviction relief)