State v. Molina
2024 UT App 172
Utah Ct. App.2024Background
- Jesus Molina was charged with murder following a fatal shooting after a fight on Halloween night, 2017; he fled to Mexico and was later arrested.
- The case was delayed multiple times by continuances and the COVID-19 pandemic.
- Before a scheduled pretrial justification hearing (to assess self-defense), the State offered Molina a plea deal for reduced charges and a sentencing recommendation.
- The plea agreement was tentatively approved by the district court, but the State rescinded its offer before Molina formally pled, citing lack of prosecutor authorization.
- Molina moved to enforce the plea, arguing detrimental reliance—he had, for example, called off defense witnesses.
- The district court agreed with Molina and ordered specific performance; the State appealed.
Issues
| Issue | Molina’s Argument | State’s Argument | Held |
|---|---|---|---|
| Did Molina detrimentally rely on the rescinded plea agreement, thus making it enforceable? | Molina presented privileged negotiations to the court, called off witnesses, and delayed hearing, arguing these show reliance. | No detrimental reliance: Molina’s actions (calling off witnesses, admitting facts) were voluntary, not compelled by the State or agreement; no actual harm. | No detrimental reliance shown; district court erred in finding otherwise. Reversed and remanded. |
Key Cases Cited
- State v. Francis, 424 P.3d 156 (Utah 2017) (sets standard that detrimental reliance can make a withdrawn plea agreement enforceable, but not every lost opportunity or procedural change constitutes such reliance)
- Santobello v. New York, 404 U.S. 257 (U.S. 1971) (emphasizes importance of plea bargaining in criminal justice system)
- State v. Levin, 144 P.3d 1096 (Utah 2006) (discusses standards for reviewing mixed law/fact questions)