Cijka v. State

CourtVermont Superior Court
DecidedFebruary 4, 2026
Docket24-cv-742
StatusUnknown

This text of Cijka v. State (Cijka v. State) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cijka v. State, (Vt. Ct. App. 2026).

Opinion

7ermont Superior Court Filed 01/30/26 RutlanP eat

VERMONT SUPERIOR COURT CIVIL DIVISION Rutland Unit Case No. 24-CV-00742 83 Center St Rutland VT 05701 802-775-4394 www.vermontjudiciary.org

Adam Cijka v State of Vermont

Decision on Cross-Motions (Nos. 6 and 11) for Summary Judgment

In this postconviction relief (PCR) case, Petitioner Adam Cijka seeks to vacate numerous convictions entered following guilty pleas at separate change-of-plea hearings on July 25, 2018, and July 31, 2024. He claims a wide variety of Rule 11 violations, involuntariness generally as to the 2018 hearing due to alleged confusion over the terms of his plea agreement, and rampant ineffective assistance of counsel by all his defense attorneys. He also claims that the 2018 sentencing judge entered an illegal sentence in violation of both statute and the operative plea agreement. The parties have filed cross- motions for partial summary judgment. The State's motion exclusively addresses the single Rule 11 violation claimed to have occurred at the 2024 change-of-plea hearing.! Mr. Cijka's motion addresses all claims raised in the third amended complaint other than ineffective assistance of counsel and a claim that the profligate errors of the 2018 proceeding somehow fundamentally undermined his completely separate sentencing the 2024?

Summary judgment shall be granted when the moving party shows that there is no genuine issue as to any material fact, "and the movant is entitled to a judgment as a matter of law." V.R.C.P. 56(a). Although the court gives the nonmoving party "the benefit of all reasonable doubts and inferences in determining whether there is a genuine issue of material fact, the nonmovant bears the burden of submitting credible documentary evidence or affidavits sufficient to rebut the evidence of the moving party." Ziniti v. New England Cent. R.R., Inc., 2019 VT 9, J 14, 209 Vt. 433 (quotation omitted). "On a petition for PCR, the petitioner must establish 'by a preponderance of the evidence that one or more fundamental errors rendered his conviction defective." PCR is a limited remedy, and the petitioner bears 'the burden of proving that fundamental errors rendered his conviction defective.'" Jn re J Brown, 2015 VT 107, 9, 200 Vt. 116 (citations omitted).

' The State's motion addresses both claims of the second amended complaint vis-a-vis the 2024 proceeding: ineffective assistance and a Rule 11 violation. After the State filed its motion, Mr. Cijka amended his complaint to withdraw this ineffective assistance claim (the ineffective assistance claims vis-a-vis the 2018 proceeding remain in the case). Accordingly, the court treats the State's motion as addressing the Rule 11 violation only, as asserted in the third amended complaint.

? While the State filed no opposition to Mr. Cijka's motion, the court does not take its silence as a concession or stipulation that he is entitled to relief. The parties to a PCR case cannot simply agree to relief; a substantive basis for PCR must be established, one way or another. See Palmer v. Furlan, 2019 VT 42, § 14, 210 Vt. 375 (Eaton, J., concurring) (""We have long cautioned that the PCR statutes 'are not intended as general sentence review statutes' and '[t]hey do not permit a successful attack on a valid sentence.""). The material facts, to the extent presented, are undisputed. They consist largely of the procedural history of the various criminal cases, the plea agreements, and the transcripts of the change-of-plea and sentencing hearings, to which the court refers below as contextually required.

The 2018 change-of-plea hearing focused on a “global” plea agreement resolving numerous dockets and charges, appearing in writing on 5 “notice of plea agreement” forms. The agreement contemplated guilty pleas to the following charges:

Form 1 1212-11-16 Rdcr — 3 counts of uttering a forged instrument (UFI)

Form 2 1402-2-16 Rdcr — 1 count of UFI 1131-10-16 Rdcr — 2 counts of violating conditions of release (VCR)

Form 3 1255-11-16 Rdcr — 1 count of UFI 1114-10-16 Rdcr — 1 count of possession of stolen property (felony) (PSP(f)) 1196-10-16 Rdcr — 1 count of UFI

Form 4 677-6-18 Rdcr — 2 counts of burglary

Form 5 147-2-17 Rdcr — 1 count of identity theft (first offense)

The 2024 change-of-plea hearing resolved 23-CR-12307 and contemplated a plea of guilty to 1 count of burglary.

Claimed confusion regarding the 2018 plea agreement

Mr. Cijka argues that his 2018 pleas were involuntary. His argument is twofold. First, he argues that the plea agreement itself was exceptionally confusing, and that confusion was compounded by the complex exchange between the judge and lawyers at the beginning of the hearing as they attempted to clarify it, at the end of which Mr. Cijka could not reasonably have been expected to understand any of it. He then reframes the same argument in the context of the myriad other errors that he now detects at the hearing (and in relation to his sentencing) to conclude that, in combination, his pleas were not knowing, intelligent, and voluntary. The court addresses the first argument only in this section. The others are addressed separately below.

“In assessing voluntariness of the plea, we consider all the circumstances.” In re Hemingway, 2014 VT 42, ¶ 15, 196 Vt. 384. “It is axiomatic that plea agreements ‘are contractual in nature and are interpreted according to contract law.’” State v. Careau, 2016 VT 18, ¶ 11, 201 Vt. 322.

The plea agreement appears in the 5 separately filled out forms described above. The agreement was “global” in the sense that the parties agreed to an aggregate sentencing range that could be no greater than a certain minimum and maximum incarcerative term, leaving the judge to fashion an effective sentence no greater than those terms. Forms 1–4 state in the “other” box: “The State is capped at arguing for a controlling sentence not to exceed a minimum sentence of 4 year [sic] and a maximum sentence not to exceed 14 years. The defense may argue for any lawful sentence.” The agreement does not limit the judge’s ability to impose a term of probation or an entirely probationary sentence, and, with one exception, it does not limit the judge’s ability to impose sentences as concurrent or consecutive to one another. The exception is Form 5. Its “other” box says: “State is capped at 4–14 years to serve, concurrent to defendant’s pending . . . charges.” Whereas on Forms 1–4 neither option for a concurrent nor consecutive sentence is selected, on Form 5 concurrent is circled.

Judges have “wide discretion to fashion appropriate sentences” within the terms of applicable statutes and accepted plea agreements. State v. Lumumba, 197 Vt. 315, 327 (2014). It is clear on the face of this agreement that the aggregate sentence could not exceed 4–14 years, could include a term of probation, and the various subsidiary sentences could be either concurrent or consecutive, but the sentence for the Form 5 conviction (identity theft) had to be concurrent.

There was confusion, however. The parties agreed that the State would be further limited as to what it could argue in relation to certain of the subsidiary sentences. For example, the parties agreed that in docket 1255-11-16 Rdcr, the State could not argue for a sentence exceeding 4–10 years for the count of uttering a forged instrument, while (as with all charges) Mr. Cijka retained the right to argue for any lawful sentence. While not confusing on its own, the prosecutor had indicated these argumentation limits on the Forms by writing them in in the min. and max. areas as though the limits themselves were agreed upon sentences. This was the only confusion over the terms of the plea agreement.

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Related

Coyle v. Hofmann
2009 VT 46 (Supreme Court of Vermont, 2009)
In re Hemingway
2014 VT 42 (Supreme Court of Vermont, 2014)
State v. Lumumba
2014 VT 85 (Supreme Court of Vermont, 2014)
State v. Medina
355 P.3d 108 (Oregon Supreme Court, 2015)
In re Derrick Brown
2015 VT 107 (Supreme Court of Vermont, 2015)
State v. James Careau
2016 VT 18 (Supreme Court of Vermont, 2016)
In re Alexis Gabree
2017 VT 84 (Supreme Court of Vermont, 2017)
Matthew Ziniti v. New England Central Railroad, Inc.
2019 VT 9 (Supreme Court of Vermont, 2019)
Stephan Palmer, Sr. v. Mark Furlan and State of Vermont
2019 VT 42 (Supreme Court of Vermont, 2019)
In re Michael Lewis
2021 VT 24 (Supreme Court of Vermont, 2021)
Miller v. State
693 N.E.2d 602 (Indiana Court of Appeals, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
Cijka v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cijka-v-state-vtsuperct-2026.