People v. Spragans CA1/4, A142695

On January 30, 2014, Dameon Spragans pleaded guilty to forcible rape (in concert), forcible oral copulation (in concert), and forcible sodomy (in concert) pursuant to a plea agreement that required him to testify truthfully against two co-defendants; prosecution dismissed other counts and recommended a 31‑year term if he complied.
The underlying offenses involved the kidnapping and repeated sexual assaults of a female victim in February 2010; DNA and other physical evidence linked the defendants to the crime.
Spragans later refused to testify, moved to withdraw his plea, and filed multiple Marsden motions to replace appointed counsel, arguing coercion, conflict, and ineffective assistance; the trial court denied those motions after in‑camera hearings.
The trial court denied Spragans’s motion to withdraw his guilty plea, found no cause to allow withdrawal, and subsequently sentenced him to the maximum exposure on the admitted charges: 42 years in prison.
The trial court also denied a certificate of probable cause under Penal Code § 1237.5; appointed appellate counsel filed a Wende brief and Spragans did not submit a supplemental brief.
On independent review, the Court of Appeal affirmed the denial of the Marsden motions, the denial of the motion to withdraw the plea, the sentence, and the denial of a certificate of probable cause.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Spragans)	Held
Whether the trial court erred by denying Marsden motions to replace counsel	Trial court properly considered Marsden claims and denied relief	Counsel was ineffective / conflict existed and coerced plea	Denial affirmed; no error found in Marsden rulings
Whether Spragans could withdraw his guilty plea after refusing to testify	Plea was knowing, voluntary, and conditioned on testimony; no cause to withdraw	Plea was coerced, pressured, insufficient time to consider, familial pressure not to testify, and counsel misconduct	Denial affirmed; defendant failed to show cause to withdraw plea
Whether the sentence (42 years) was improper given plea agreement recommending 31 years	Court had discretion; plea agreement conditioned on truthful testimony; defendant breached condition	Defendant claims he misunderstood collateral consequences and was pressured	Sentence affirmed; court did not err in imposing maximum on admitted counts
Whether to grant certificate of probable cause for appeal under § 1237.5	Appellant waived appellate rights in plea paperwork; certificate properly denied	Waiver contested; appellant argued appellate rights were not waived and listed trial errors	Denial of certificate affirmed; appellate review under Wende found no reversible issues

Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (courts must ensure guilty pleas are made voluntarily with waiver of constitutional rights)
In re Tahl, 1 Cal.3d 122 (Cal. 1969) (requirements for a knowing and voluntary plea in California)
People v. Wende, 25 Cal.3d 436 (Cal. 1979) (appellate counsel may file brief requesting independent record review when no arguable issues are identified)
People v. Marsden, 2 Cal.3d 118 (Cal. 1970) (procedure for defendant to seek replacement of appointed counsel)
People v. Breslin, 205 Cal.App.4th 1409 (Cal. Ct. App. 2012) (discusses standard for withdrawal of guilty pleas)
People v. Maultsby, 53 Cal.4th 296 (Cal. 2012) (procedures and effect of a § 1237.5 certificate of probable cause)