Background

• Campbell pled guilty to murder under a plea agreement; the State dismissed eight other charges and sentenced determined by the court with possible life without parole.
• Campbell agreed to testify fully at proceedings regarding the offenses, including co-defendants.
• At a co-defendant trial Campbell refused to testify, leading to direct criminal contempt and a 2.5-year sentence.
• The State moved to withdraw from the Plea Agreement and vacate the judgment of conviction.
• The trial court granted the State’s withdrawal, vacated the conviction, and ordered trial on the original charges.
• Campbell petitioned for interlocutory review, which the appellate court granted and accepted jurisdiction.

Issues

Key Cases Cited

• Griffin v. State, 756 N.E.2d 572 (Ind. Ct. App. 2001) (contractual interpretation of plea agreements; performance matters)
• Reffett v. State, 571 N.E.2d 1227 (Ind. 1991) (court-bound by plea terms within power to control; cannot revoke after acceptance)
• Epperson v. State, 530 N.E.2d 743 (Ind. Ct. App. 1988) (due process safeguards in plea negotiations; remedies for breach)
• Spivey v. State, 553 N.E.2d 508 (Ind. Ct. App. 1990) (defendant’s deception may void plea; breach mechanics)
• Lineberry v. State, 747 N.E.2d 1151 (Ind. Ct. App. 2001) (plea bargains; necessity of fair consideration and performance)
• Roeder v. State, 696 N.E.2d 62 (Ind. Ct. App. 1998) (breach remedies; withdrawal or specific performance considerations)
• Bowers v. State, 500 N.E.2d 203 (Ind. 1986) (public interest in using plea agreements; benefits to justice system)
• Downs v. State, 827 N.E.2d 646 (Ind. Ct. App. 2005) (policy against allowing breach to undermine plea usefulness)
• Mendoza v. State, 869 N.E.2d 546 (Ind. Ct. App. 2007) (withdrawal timing in relation to trial; consideration of detriment)
• Kelly v. Levandoski, 825 N.E.2d 850 (Ind. Ct. App. 2005) (consideration as essential element in contract-like plea bargains)