State of Minnesota v. Chaz Jacobi Beckman
A16-0635
| Minn. Ct. App. | Feb 6, 2017Background
- Beckman was charged with first-degree drug possession and related misdemeanors and pleaded guilty under a written Rule 15 petition to amended second-degree possession in exchange for dismissal of other charges and the State’s agreement to remain silent on any departure motion and cap any jail recommendation at 120 days if the court granted a departure.
- At the plea hearing the State placed on the record that its silence and other aspects of the plea agreement were contingent on Beckman cooperating with the PSI and abiding by conditions of release; Beckman, under oath, acknowledged understanding and accepted those contingencies.
- Beckman failed to enroll in Teen Challenge, violated release conditions, was re-arrested, and the court issued a bench warrant; the State then argued it was no longer bound by its silence/agreements at sentencing.
- At sentencing Beckman asked either a second furlough to enter Teen Challenge or to withdraw his plea; the district court denied plea withdrawal and denied a downward dispositional departure, imposing a 98‑month prison sentence within the guidelines.
- Beckman appealed, arguing the plea was involuntary due to an unfulfilled promise (the State’s silence), that plea withdrawal was fair and just, and that the court abused its discretion by failing to consider departure factors fully.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Beckman’s guilty plea was involuntary (manifest injustice) because the State failed to honor an agreed silence at sentencing | Beckman: plea induced by State promise to remain silent as in written petition; that promise was unfulfilled, rendering plea involuntary | State: plea‑hearing record shows the State’s silence was expressly contingent on Beckman cooperating with the PSI and obeying release conditions; Beckman acknowledged contingency | Court: No manifest injustice; plea was voluntary because the transcript shows Beckman understood the State’s obligation was conditional and he violated those conditions |
| Whether withdrawal of plea was fair and just under Minn. R. Crim. P. 15.05, subd. 2 | Beckman: should be allowed to withdraw to get another chance at Teen Challenge and accept risk of higher sentence; also claimed criminal‑history score error | State: relied on plea and Beckman had repeated opportunities to comply; withdrawal would be unjustified | Court: No abuse of discretion; Beckman failed to advance sufficient substantive reasons for withdrawal despite State not showing prejudice |
| Whether the district court abused discretion by denying a downward dispositional departure for probation | Beckman: court failed to consider Trog factors favoring departure (age, remorse, support, rehab steps) | State: court considered mitigating evidence but properly weighed it against long history of failing probation and noncompliance | Court: No abuse of discretion; court considered circumstances for and against departure and permissibly imposed a presumptive sentence |
Key Cases Cited
- Raleigh v. State, 778 N.W.2d 90 (Minn. 2010) (standard for voluntariness and fair‑and‑just plea withdrawal review)
- Nelson v. State, 880 N.W.2d 852 (Minn. 2016) (guilty plea must be accurate, voluntary, and intelligent)
- Uselman v. State, 831 N.W.2d 690 (Minn. App. 2013) (plea involuntary if it rests to any significant degree on an unfulfilled promise)
- Miller v. State, 754 N.W.2d 686 (Minn. 2008) (factual vs. legal review of plea‑agreement interpretation)
- Bertsch v. State, 707 N.W.2d 660 (Minn. 2006) (appellate review of dispositional‑departure denials is abuse‑of‑discretion)
- Trog v. State, 323 N.W.2d 28 (Minn. 1982) (factors for assessing whether defendant is particularly amenable to probation)