Wheeler v. State
| Decision Date | 21 March 2018 |
| Docket Number | A16-0835 |
| Citation | 909 N.W.2d 558 |
| Parties | Jetaun Helen WHEELER, Appellant, v. STATE of Minnesota, Respondent. |
| Court | Minnesota Supreme Court |
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.
In State v. Johnson , 279 Minn. 209, 156 N.W.2d 218, 223 (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.
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,
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 parties can agree on (something in the range of x months and 240 months) appears to be more realistic.
No agreement was reached, so the case proceeded to trial the next week. At the end of the first day of trial, the district court requested an update on negotiations: The parties confirmed this understanding, as well as defense counsel’s intention to meet with Wheeler that weekend to discuss the offer further. Wheeler alleges that at or around this time, the district court and its law clerk made additional off-the-record remarks proposing a plea to second-degree unintentional murder.
Before the start of the third day of trial, Wheeler pleaded guilty to the offense of second-degree unintentional murder under an aiding-and-abetting theory of liability. At the sentencing hearing, counsel for the State noted that "we’re all thankful that [Wheeler’s children] did not have to come ... testify, I know the [c]ourt wanted that more than anything." Defense counsel noted that Wheeler "gave up her right to trial ... to protect her children." The district court commented that it had met the children and could "tell right away ... that they were suffering[,]" so it was "appreciative of the fact that the parties were able to come to some agreement ... that kind of, sort of, prompted [Wheeler] to enter a plea to Unintentional Second Degree." The district court then sentenced Wheeler to 172 months in prison.
Over a year later, Wheeler filed a timely petition for postconviction relief, asserting that the district court had improperly participated in the plea bargaining negotiation. Citing Minnesota Rule of Criminal Procedure 15.05 and court of appeals precedent, she maintained that this judicial participation made her plea per se invalid and required plea withdrawal "to correct a manifest injustice." Wheeler’s trial counsel submitted a supporting affidavit, alleging that, but for the court’s participation, including on- and off-the-record comments, "the parties would not have agreed to a plea deal." Wheeler herself did not submit an affidavit.
The same judge that presided over Wheeler’s trial denied her petition for postconviction relief without holding an evidentiary hearing, concluding that Wheeler’s claims were merely "argumentative assertions" without factual support. The judge concluded that, despite being "unambiguously involved" in the plea negotiations, the district court had not improperly involved itself. The judge further concluded that the court’s "sparse remarks" were a "far cry from pressuring the parties to settle" and that the court never promised or suggested "anything like a specific sentence."
The court of appeals affirmed. Wheeler v. State , 889 N.W.2d 807, 809 (Minn. App. 2017). Relying heavily on our commentary about the role of judges in plea bargaining in State v. Johnson , 279 Minn. 209, 156 N.W.2d 218 (1968), and analogizing to its own precedent, the court of appeals determined that "the district court did not excessively involve itself in the plea negotiation" because the court had neither made a direct plea offer nor made a promise or threat concerning sentencing. Wheeler , 889 N.W.2d at 816.
The threshold question in this case is what it means for a district court judge to "participate" in the plea bargaining negotiation itself. Although this question is one of first impression, we do not write on a blank slate. Fifty years ago in State v. Johnson , we observed that plea bargaining was a "prevalent practice" that was "not in conflict with public policy" so long as it was "controlled by the observance of certain essential conditions." 156 N.W.2d at 222. In discussing the "role" and "responsibility" of the district court judge in the plea bargaining process, we announced the principle that "the court should [not] ... participate in the plea bargaining negotiation itself."1 Id. at 223 (emphasis added). Although our holding in Johnson did not hinge on these comments, we gave comprehensive consideration to the role of judges, prosecutors, and defense attorneys in the plea process. We must now clarify what we meant in Johnson when we said that a district court judge should not "participate" in the plea bargaining negotiation itself. See id.
"The interpretation of case law is a legal question that is reviewed de novo." State v. Robideau , 796 N.W.2d 147, 150 (Minn. 2011). Under the de novo standard, we do not defer to the analysis of the courts below, but instead we exercise independent review. Kmart Corp. v. County of Stearns , 710 N.W.2d 761, 766 n.4 (Minn. 2006).
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