People of Michigan v. Monty Lamar Jamison, 333990

Defendant Monty Jamison pleaded guilty to surveilling an unclothed person in exchange for the prosecution’s recommendation of no more than 12 months’ jail.
After the plea but before sentencing, Jamison violated bond conditions: he failed to report to court services and used marijuana (testing could not be verified after bond amendment).
At sentencing the trial court stated Jamison’s misconduct nullified the prosecutor’s recommendation and imposed 34 to 180 months’ imprisonment.
Jamison did not move to withdraw his plea in the trial court and later appealed, arguing his plea was not knowing and voluntary because he was not told his bond violations could lead the court to reject the recommendation.
The Court of Appeals treated the claim as unpreserved and reviewed for plain error, concluding Jamison committed misconduct under MCR 6.310(B)(3) and thus was not entitled to withdraw his plea.
The court affirmed the sentence, holding the plea remained valid and that the court need not expressly warn a defendant that post-plea misconduct forfeits the right to withdraw the plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jamison’s plea was not knowing, voluntary, and therefore withdrawable because he was not told post-plea bond violations could allow the court to exceed the prosecutor’s recommendation	The prosecution argued the court properly sentenced Jamison above the recommendation because he committed post-plea misconduct and was not entitled to withdraw his plea under MCR 6.310(B)(3)	Jamison argued his plea was involuntary/unknowing because he was never informed that violating bond conditions could cause the court to reject the prosecutor’s recommendation and impose a higher sentence	Court held Jamison’s claim was forfeited and, on plain-error review, rejected it: his post-plea misconduct removed any right to withdraw the plea and no due-process rule required an express warning about that consequence

People v. Armisted, 295 Mich. App. 32 (discussing plain-error review for unpreserved constitutional claims)
People v. Killebrew, 416 Mich. 189 (trial court rejection of sentence agreement can allow plea withdrawal)
People v. Kean, 204 Mich. App. 533 (post-plea noncompliance can waive right to withdraw plea)
People v. Garvin, 159 Mich. App. 38 (escape from custody waived right to withdraw plea when court rejects recommendation)
People v. Blanton, 317 Mich. App. 107 (MCR 6.302 plea requirements derive from due process)
People v. Schluter, 204 Mich. App. 60 (pre-1994 rule that plea agreements silent on restitution could preclude restitution order)
People v. Ronowski, 222 Mich. App. 58 (limiting Schluter after statutory changes made restitution mandatory)