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Wheeler v. State

Supreme Court of Minnesota

March 21, 2018

Jetaun Helen Wheeler, Appellant,
v.
State of Minnesota, Respondent.

          Court of Appeals Office of Appellate Courts

          Cathryn Middlebrook, Chief Appellate Public Defender, Chang Y. Lau, Assistant State Public Defender, Saint Paul, Minnesota, for appellant.

          Lori Swanson, Attorney General, Saint Paul, Minnesota; and Michael O. Freeman, Hennepin County Attorney, Kelly O'Neill Moller, Assistant Hennepin County Attorney, Minneapolis, Minnesota, for respondent.

         SYLLABUS

         1. The principle that a district court judge may not participate in the plea bargaining negotiation itself, which we first recognized in State v. Johnson, 156 N.W.2d 218 (Minn. 1968), is not solely a prohibition on judicial plea offers, promises, or threats. It also prohibits unsolicited judicial comments regarding the propriety of the parties' competing settlement offers.

         2. A judge does not participate in the plea bargaining negotiation by merely inquiring into the status of the parties' plea negotiations, sharing general sentencing practices, or disclosing nonbinding plea and sentencing information at the joint request of the parties.

         3. When a defendant proves that a Johnson violation has occurred, the plea is invalid only if it is involuntary under the totality of the circumstances.

         Reversed and remanded.

          OPINION

          CHUTICH, Justice.

         In State v. Johnson, 156 N.W.2d 218, 223 (Minn. 1968), we recognized the principle that a district court judge should not "participate in the plea bargaining negotiation itself." The present case requires us to clarify the meaning of "participate" and to determine the appropriate remedy when a defendant proves that the district court participated in the plea bargaining negotiation itself.

         The district court in appellant Jetaun Helen Wheeler's case made unsolicited comments about the propriety of the parties' competing settlement offers, including charges and sentences, before the parties reached an agreement for the court to accept or reject. Wheeler ultimately pleaded guilty to an amended charge during trial. Over a year later, Wheeler filed a postconviction petition, alleging that "the parties would not have agreed to a plea deal" but for the court's participation in the plea negotiations. She alleged that the court's participation made her plea invalid and required a remedy of automatic plea vacatur. The postconviction court denied her petition for postconviction relief without holding an evidentiary hearing, and the court of appeals affirmed.

         We hold that a district court "participates" in the plea bargaining negotiation when it provides unsolicited comments regarding the propriety of the parties' competing settlement offers. We also hold that, when a defendant successfully challenges the validity of a guilty plea because of the district court's participation, the remedy is not automatic invalidation and vacatur of the plea. Rather, the plea is only invalid if it was involuntary under the totality of the circumstances. Because the law in existence at the time Wheeler filed her postconviction petition did not require a defendant to establish that her guilty plea was involuntary, we reverse the court of appeals and remand to the district court to give Wheeler an opportunity to amend her postconviction petition in light of the holdings that we announce today.

         FACTS

         The State of Minnesota charged Wheeler with second-degree intentional murder in August 2013. Because Wheeler had zero criminal history points, the charge carried a presumptive duration of 306 months in prison, with a range of 261 to 367 months. See Minn. Sent. Guidelines 4.A. Shortly after Wheeler was charged, defense counsel sought a plea to manslaughter, but the State did not move off the initial charge.

         Plea negotiations were at an impasse until approximately 8 months later, when the State announced that it intended to call Wheeler's young children to testify against her. This announcement prompted the district court to become involved in the plea-negotiation process. Two weeks before trial, the court held a pretrial hearing to determine whether Wheeler's children should be allowed to testify. The court made the following on-the-record comments, in Wheeler's presence, encouraging both parties to negotiate:

I think . . . you both have done a very thorough job of evaluating your case. There are positives, I'm sure, and negatives on both sides of the coin, so to speak, and I would - really like someone to extend an offer, at least make an attempt to try to resolve this case. It is a pretty serious situation to have children of the defendant having to come to court and testify possibly against their own mother. Both of you should be considering this. So I would like to see some attempts made at trying to resolve this.

         The court further stated, "I don't care how you want to package it. . . . There [are] wins and losses on a lot of elements in this case, and you never know what the jury is going to do."

         Following this conversation, plea negotiations intensified between the parties. A week later, however, the State emailed the district court, with defense counsel copied, noting that "it does not appear that [this case] will settle" because the parties disagreed on the appropriate charge. The State had offered to reduce the charge to second-degree unintentional murder with a sentence of 240 months, and defense counsel had offered a plea to second-degree manslaughter with a sentence between probation and 96 months in prison.

         The district court responded to both attorneys with unsolicited comments on the propriety of each party's settlement offer:

Thank you for the efforts you all have put towards settling this case. . . . The defendant's offer to enter a straight plea to manslaughter in the second degree with a waiver of Blakely for a double departure of 96 months in prison, much less for a probationary disposition, isn't something this court is willing to do. Given what facts the court is aware of, a plea to unintentional 2nd degree murder with a prison term the ...

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