Roberts v. State
298 Ga. 331
Ga.2016Background
- In July 2006 Ian Mosley was kidnapped in South Carolina; Roberts, Demeric Twitty, and Edward Reeves drove him to Augusta, GA, where Twitty shot Mosley in the head and the body was dumped in the Savannah River.
- Roberts was captured days later using Mosley’s phone and credit card and possessing a shotgun obtained in exchange for the murder weapon.
- Roberts was indicted on malice murder, felony murder, and related firearm charges; charges against Roberts were reindicted in 2007.
- Roberts pled guilty to felony murder on August 19, 2008; malice murder and the firearm count were nolle prossed, and he received life with parole per the plea agreement.
- Roberts appealed, arguing the plea lacked a sufficient factual basis and was not intelligently made because the State allegedly had a secret plea deal with Reeves that was not disclosed to him.
Issues
| Issue | Plaintiff's Argument (Roberts) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the guilty plea had a sufficient factual basis | Plea lacked adequate factual recitation to support felony murder | Prosecutor (and Roberts’s lawyer) recited facts at the plea hearing sufficient to support felony murder as principal or party | Plea supported: prosecutor’s recitation satisfied court that factual basis existed; no error |
| Whether the plea was intelligently made because of alleged undisclosed deal with Reeves (Brady claim) | Plea was uninformed because State secretly offered Reeves a favorable deal and suppressed that information | No evidence State suppressed any deal or that any undisclosed agreement existed or would have changed Roberts’s decision to plead; Roberts pled before any witness testimony | Plea was intelligent: court informed Roberts of rights and consequences; Roberts indicated understanding; no Brady violation shown |
Key Cases Cited
- Freeman v. State, 297 Ga. 146 (2015) (factual-basis standard for guilty pleas)
- Adams v. State, 285 Ga. 744 (2009) (trial-court acceptance of plea reflects satisfaction with recitation of facts)
- Franks v. State, 278 Ga. 246 (2004) (no Brady violation where defendant fails to show State suppressed favorable evidence)
- Boykin v. Alabama, 395 U.S. 238 (1969) (trial court must ensure plea is voluntary and made with knowledge of rights waived)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially exculpatory evidence)
- Sanders v. State, 280 Ga. 780 (2006) (defendant is not entitled to have court accept a plea or to a more favorable plea than offered)