156 A.3d 131
Me.2017Background
- John P. Stevens was indicted (July 2015) for receiving stolen property (alleged sale of CMP copper wire).
- On the day of trial, after jury selection, Stevens—represented by counsel—entered an unconditional (open) guilty plea.
- The trial court conducted a Rule 11 colloquy and accepted the plea; Stevens did not move to withdraw the plea before sentencing.
- Six weeks later the court sentenced Stevens to four years’ imprisonment; concurrent misdemeanor sentences were also imposed.
- Stevens appealed, arguing the Rule 11 inquiry was incomplete because the court failed to ask whether he was aware of and understood any prior plea negotiations. The State moved to dismiss the appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court was required during its Rule 11 colloquy to ask if Stevens understood consequences of any prior plea negotiations to establish voluntariness | Stevens: Rule 11 required the court to ask whether he was aware of and understood any plea negotiations preceding the plea | State: Direct appeal from an unconditional guilty plea is improper except for challenges to jurisdiction or constitutionality of the sentence; such Rule 11 claims are collateral and belong in post‑conviction review | Appeal dismissed; claim that Rule 11 was incomplete must be pursued via post‑conviction review (no jurisdiction to consider on direct appeal) |
Key Cases Cited
- State v. Huntley, 676 A.2d 501 (Me. 1996) (direct appeals after unconditional guilty pleas are limited to jurisdictional or punishment challenges; voluntariness claims are collateral)
- State v. Pfeil, 720 A.2d 573 (Me. 1998) (post‑conviction review is the appropriate forum for resolving voluntariness and Rule 11 noncompliance because an evidentiary hearing may be required)
- State v. Gach, 901 A.2d 184 (Me. 2006) (dismissal of direct appeal after unconditional plea where none of the limited exceptions applied)
- State v. Plummer, 939 A.2d 687 (Me. 2008) (reaffirming Huntley: absent a conditional plea, motion to withdraw before sentencing, or jurisdiction/punishment challenge, appeals after unconditional pleas are dismissed)