People v. Hoy

158 N.W.2d 436, 380 Mich. 597, 1968 Mich. LEXIS 166
CourtMichigan Supreme Court
DecidedMay 6, 1968
DocketCalendar 18, Docket 51,563
StatusPublished
Cited by12 cases

This text of 158 N.W.2d 436 (People v. Hoy) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Hoy, 158 N.W.2d 436, 380 Mich. 597, 1968 Mich. LEXIS 166 (Mich. 1968).

Opinions

BbeNNAN, J.

Frederick Hoy was convicted of being drunk or intoxicated in a public place, third offense.1 Upon a plea of guilty entered October 9, 1964, in circuit court he was sentenced to a term of 1-1/2 to 2 years in State’s prison.

A petition to vacate sentence, plea, and for a new trial was filed on his behalf, and on January 22, 1965, a hearing was held on this petition. The twofold thrust of this petition was that the defendant “unknowingly believed that an attorney could not be of any assistance to him,” and. that defendant has been subjected to cruel and unusual punishment. Ploy had been represented by counsel at an earlier stage of the proceedings. The testimony of Mr. Hoy at the January 22d hearing with respect to the matter of counsel is as follows:

“Q. Now, in your petition, you say in the first paragraph, that at the time of your arraignment, you unknowingly believed that an attorney could not be of any assistance to you. Now, is that true, that at the time of the arraignment when you had Mr. Libby there and you wanted him to go ahead with you and stay with you, but the only problem was money, or he would have gone through with the trial; having that in mind, is it true, that at the time of the arraignment, you believed you didn’t need a lawyer because a lawyer couldn’t do you any good?
[601]*601“A. I didn’t even give it any thought, as soon as I was bound over to circuit court, I put up nay bond and went and got a lawyer.
“Q. Well, now, did you read this petition that was filed here in the last few weeks by Mr. Kingsley in your behalf?
“A. Yes, sir, I did.
“Q. Now, just look at the last sentence in the first paragraph, it says he, that’s you, ‘he unknowingly believed that an attorney could not be of any assistance to him.’
“Did you believe that an attorney could not be of any assistance to you?
“A. I believed, toward the end, I believed that an attorney couldn’t be of any assistance to me, because I would be convicted of this third offense drunkenness, anyway.
“Q. You figured you couldn’t win?
“A. That’s right.
“Q. That was after you ran out of money, is that correct?
“A. Yes.
“Q. But you knew that the Court would have given you a lawyer if you needed one and didn’t have money?
“A. Well, it was never fully clear to me at the time, no. I mean, no one would appeal for me after I was sentenced, until I talked it over with some guys who said you could.
“Q. Now, your second paragraph says that you ‘were ignorant of any defense and didn’t therefore avail yourself of a right to trial.’
“Is this correct, that you were ignorant of any defense? Mr. Libby didn’t indicate that you had any defense, is that right?
“A. Yes, sir, he never came right out and said anything about this package here, or anything like that; that I could fight it, he never said anything.
[602]*602“Q. Okay.
“Ñów, do I understand correctly, that what yon are challenging now is, that a sick man ought not to be in jail, is that correct?
“A. Yes, sir.
“Q. Yon are not challenging the fact that you were drunk and disorderly in a public place on the day in ■question, is that correct?
“A. Yes, sir.
“Q. So, it is not the conviction you are talking about, but the sentence, is that correct?
“A. Yes, sir.”

The petition for a new trial alleges that the principle enunciated in the case of Robinson v. California (1962), 370 US 660 (82 S Ct 1417, 8 L ed 2d 758), is applicable in Hoy’s defense, that such a defense has not been previously recognized in the State of Michigan, and that this case is a test case. The substantive defense presented on Mr. Hoy’s behalf •is as follows: Hoy is a chronic alcoholic. Alcoholism is a disease. Imprisonment for having a disease is cruel, unusual punishment, contrary to the Eighth Amendment to the United States Constitution.

This case raises two issues:

1. Whether a plea of guilty is free and voluntary where the accused, after consultation with a lawyer, enters the plea believing that he has no legal defense and subsequently learns of a novel legal theory upon which a test case could have been predicated.

Perhaps this issue can be restated as follows: Was defendant denied the assistance of competent counsel for his defense where his lawyer did not advise him of the possibility of defending on a theory which never has been known to have been advanced in this State? Defendant Hoy pled guilty to a third offense of being drunk in a public place. This petition seeks to vacate his conviction, set aside his plea, and obtain for him a new trial. At such new trial, it is [603]*603proposed to show that the defendant is an alcoholic. And it is proposed to be argued that conviction of an alcoholic for this offense is unconstitutional.

Before a new trial can he reached, the conviction and plea must he vacated. And it must he shown that there was a substantial constitutional defect in the plea and conviction before we can reach the stage of considering the substantive constitutional defense based upon alcoholism.

It is conceded that Mr. Hoy had the benefit of a lawyer at some time prior to the entry of the plea. We can assume from this record that his lawyer did not tell him about the case of Robinson v. California, supra, or suggest that he might be defended on a theory analogous to that case. Prom this record we conclude that Mr. Hoy pled guilty in the belief that he had no valid defense to the charge. If Mr. Soy’s belief was erroneous and arrived at after consultation with an incompetent lawyer, through whose demonstrable ineptitude he was kept in the dark, it could then be said that Mr. Hoy’s plea suffered the constitutional infirmity of having been made without the assistance of counsel.

We do not believe it prudent to brand a lawyer with the stigma of professional incompetence because he is so naive as to presume that the law is what it has always been considered to be. Neither do we see the wisdom of encouraging the inmates of our penal institutions to become trail blazers. If incompetence of counsel flows automatically from every after-discovered defense, then the question of whether a defendant has a competent lawyer can never be determined as of the time of the plea, and no plea could be accepted except on the condition, that the subsequent development of the law does not later make the plea retrospectively ill-advised- •

[604]

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People v. Hoy
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Bluebook (online)
158 N.W.2d 436, 380 Mich. 597, 1968 Mich. LEXIS 166, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hoy-mich-1968.