State v. Adams
8 N.E.3d 984
Ohio Ct. App.2014Background
- Defendant Lamar Adams pled Alford to felonious assault in exchange for the state to stand silent and make no sentencing recommendation, as stated in the written plea and at the plea hearing.
- At sentencing, a different assistant prosecutor advocated for the maximum eight-year sentence, contrary to the plea agreement to remain silent.
- The victim testified to extensive injuries and ongoing fear, and defense emphasized PTSD and relatively minimal prior criminal history.
- The trial court sentenced Adams to six years in prison after considering the state's recommendation, which breached the plea agreement.
- The court recognized plain error but did not vacate the plea; it reversed and remanded for a new sentencing hearing before a different judge, with the state bound to comply with the agreement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the breach voids the plea | Adams (State) breached by seeking eight years. | Breach invalidates the plea; withdrawal or specific performance required. | Plain error found; remand for resentencing before a different judge. |
| Remedy for plea breach | Remand with new sentencing aligned to agreement not vacating plea. | Vacation of the plea or resentencing is appropriate. | Remand for new sentencing before a different judge; state must abide by agreement. |
Key Cases Cited
- Santobello v. New York, 404 U.S. 257 (U.S. Supreme Court (1971)) (promises in plea negotiations must be fulfilled; remand possible)
- Puckett v. United States, 556 U.S. 129 (U.S. Supreme Court (2009)) (plain-error review applicable; determine if outcome would differ)
- Barnes v. United States, 278 F.3d 644 (6th Cir. 2002) (remand for resentencing when plea agreement to recommend low end not honored)