Vaughn v. State
158 A.3d 1060
| Md. Ct. Spec. App. | 2017Background
- In 2004 Michael Vaughn pled guilty in Baltimore City to third-degree sexual offense; plea agreement and sentencing (five years suspended, three years probation) explicitly required sex-offender registration and counseling.
- The factual proffer at plea described vaginal intercourse with a 12-year-old victim; defense counsel did not place the statutory elements of third-degree sexual offense on the record.
- In 2015 (eleven years later) Vaughn filed a petition for a writ of error coram nobis, arguing the factual predicate was insufficient for third-degree sex offense and the plea was not knowing because elements were not explained.
- Vaughn relied on the collateral consequence of mandatory sex-offender registration as a basis for coram nobis relief; his filings asserted the registration had an enormous life impact but lacked affidavit detail.
- The State replied that Vaughn knew of the registration requirement at plea, that the plea provided a significant benefit (avoiding a second-degree rape conviction), and that coram nobis requires alleging significant collateral consequences.
- The circuit court denied relief, finding registration was a condition of the plea (not an unexpected collateral consequence) and Vaughn failed to show a significant unforeseen consequence; Vaughn appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory sex-offender registration satisfies Skok's "significant collateral consequence" requirement for coram nobis when the petitioner knew of registration at plea | Vaughn: registration is a severe collateral consequence entitling him to coram nobis relief | State: registration was disclosed at plea and thus is a condition of the plea, not an unforeseen collateral consequence | Court: No — collateral consequence must be one the petitioner did not know about when entering the plea; knowing registration does not meet Skok requirement |
| Whether the guilty plea was not knowingly, voluntarily, and intelligently entered because the elements of third-degree sexual offense were not explained on the record | Vaughn: plea lacked element-by-element advisement; thus infirm and subject to coram nobis | State: plea colloquy and factual proffer were sufficient; plea conferred benefit and was knowing | Court: Rejected Vaughn’s coram nobis challenge on grounds that he failed to meet Skok’s collateral-consequence requirement; did not grant relief based on plea-advisement claim |
| Whether the factual proffer was insufficient to support third-degree sexual offense (argument that intercourse is not "sexual contact") | Vaughn: proffer did not prove "sexual contact" under the statute; facts better support second-degree offense | State: proffer included kissing and facts sufficient to support the charged offense; plea benefited Vaughn by avoiding more serious charge | Court: Did not grant coram nobis; concluded procedural bar (no unforeseen collateral consequence) fatal to petition regardless of merits of predicate sufficiency |
Key Cases Cited
- Skok v. State, 361 Md. 52 (2000) (adopting Morgan framework for coram nobis and requiring petitioner show significant collateral consequences not known at plea)
- United States v. Morgan, 346 U.S. 502 (1954) (federal delineation of coram nobis scope)
- Bayne v. State, 98 Md. App. 149 (1993) (statutory interpretation of "sexual contact" referenced by petitioner)
- Coleman v. State, 219 Md. App. 339 (2014) (noting coram nobis is extraordinary and relief is granted only to achieve justice in extreme cases)
- Bousley v. United States, 523 U.S. 614 (1998) (guilty-plea finality concerns and limits on collateral attack)
- United States v. Denedo, 556 U.S. 904 (2009) (emphasizing finality and cautious use of extraordinary collateral remedies)