State v. Jeffries
2011 Minn. LEXIS 643
| Minn. | 2011Background
- Jeffries pled guilty to felony domestic assault in June 2008 under a plea deal for a 48-month stayed sentence; the court later indicated it would not accept the deal and returned the pleas, setting a trial for October 2008.
- A second plea was entered in March 2009 resulting in an executed 60-month sentence after Jeffries violated release conditions by possessing marijuana.
- The district court vacated the first guilty plea and found Jeffries not guilty, then proceeded with a second plea and sentencing.
- Jeffries appealed alleging double jeopardy and ineffective assistance of counsel; the court of appeals affirmed, and the supreme court granted review.
- The supreme court reverses and remands, vacating the second conviction and reinstating/resentencing on the first conviction; the ineffective-assistance issue is not reached.
- There are concurring and multiple dissenting opinions addressing when jeopardy attaches and whether the first conviction occurred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jeffries was convicted at the first plea hearing. | Jeffries argues the court unconditionally accepted and recorded a conviction. | State contends no unconditional acceptance/recording occurred. | Yes; first plea hearing produced a conviction for double jeopardy purposes. |
| Whether the second conviction violated the Double Jeopardy Clause despite the first conviction. | State argues forfeiture bars appeal; no second conviction occurs. | Jeffries asserts double jeopardy protections bar second prosecution after conviction. | Second conviction vacated; double jeopardy violation, remedy to reinstate first conviction. |
| Whether Jeffries forfeited his double-jeopardy claim by pleading again. | State claims forfeiture under plea rules. | Menna controls; counseled guilty plea not a blanket forfeiture. | Menna binding; claim not forfeited; second conviction vacated. |
| What is the appropriate remedy for a double-jeopardy violation in this case. | Remedy should vacate second conviction and keep punishment under first plea. | Remand for resentencing on the first conviction; second conviction vacated. |
Key Cases Cited
- Brown v. Ohio, 432 U.S. 161 (1977) (double jeopardy bars second prosecution after conviction for same offense)
- Minn. v. Martinez-Mendoza, 804 N.W.2d 1 (Minn. 2011) (state court rules on plea withdrawals and recording in light of sentencing)
- Menna v. New York, 423 U.S. 61 (1975) (counseled guilty plea does not bar double-jeopardy appeal if record supports other grounds)
- State ex rel. Boswell v. Tahash, 278 Minn. 408, 154 N.W.2d 813 (1967) (forfeiture rule; later decisions constrained by federal law)
- State v. Thompson, 754 N.W.2d 352 (Minn. 2008) (postponed acceptance vs. unconditional acceptance; when conviction occurs)
- United States v. Ball, 163 U.S. 662 (1896) (excursus on continuing jeopardy and retrial after conviction)
- Crist v. Bretz, 437 U.S. 28 (1978) (jeopardy attaches in jury trial when empaneled and sworn; related principles for guilty pleas)