State of Minnesota v. William James Chestnut
This text of State of Minnesota v. William James Chestnut (State of Minnesota v. William James Chestnut) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
This opinion will be unpublished and may not be cited except as provided by Minn. Stat. § 480A.08, subd. 3 (2014).
STATE OF MINNESOTA IN COURT OF APPEALS A15-1073
State of Minnesota, Respondent,
vs.
William James Chestnut, Appellant.
Filed April 25, 2016 Affirmed Stauber, Judge
Ramsey County District Court File No. 62CR143332
Lori Swanson, Attorney General, St. Paul, Minnesota; and
John J. Choi, Ramsey County Attorney, Peter R. Marker, Assistant County Attorney, St. Paul, Minnesota (for respondent)
Cathryn Middlebrook, Chief Appellate Public Defender, Sharon E. Jacks, Assistant Public Defender, St. Paul, Minnesota (for appellant)
Considered and decided by Stauber, Presiding Judge; Connolly, Judge; and Reilly,
Judge. UNPUBLISHED OPINION
STAUBER, Judge
On appeal from his conviction of second-degree unintentional murder, appellant
argues that his 225-month sentence must be reduced because he pleaded guilty in
exchange for a 144-month sentence. We affirm.
FACTS
Appellant William Chestnut was charged with one count of second-degree
intentional murder and one count of second-degree unintentional murder. Appellant
subsequently pleaded guilty to second-degree unintentional murder and the second-
degree intentional murder charge was dismissed. At sentencing, appellant complained
that the prosecutor “switched” the plea agreement. According to appellant, the
prosecutor told him that the plea agreement was for “18, do 12.”1 The district court
disagreed with appellant’s recollection that the agreement was for appellant to serve 12
years, and sentenced appellant to 225 months in prison. This appeal followed.
DECISION
Plea agreements represent bargained-for understandings between the state and
defendants, where each party foregoes rights and assumes risks in exchange for certainty
regarding the outcome of a criminal proceeding. State v. Meredyk, 754 N.W.2d 596, 603
(Minn. App. 2008). Contract-law principles are relevant to the interpretation of plea
1 An executed sentence, for an offense committed after August 1993, consists of two parts: a term of imprisonment that is generally equal to two-thirds of the executed sentence, and a supervised release term generally equal to one-third of the executed sentence. Minn. Stat. § 244.101, subd. 1 (2012).
2 agreements. State v. Spaeth, 552 N.W.2d 187, 194 (Minn. 1996). The determination of
the terms of a plea agreement is a factual inquiry. State v. Rhodes, 675 N.W.2d 323, 326
(Minn. 2004). In order to determine whether the parties have honored a plea agreement,
this court first looks to what the parties “reasonably understood to be the terms of the
agreement.” State v. Brown, 606 N.W.2d 670, 674 (Minn. 2000) (quotation omitted).
Ambiguities in plea agreements are construed in favor of defendants. In re Ashman, 608
N.W.2d 853, 858 (Minn. 2000).
Appellant argues that his consistent indications “throughout the proceedings that
he believed he was pleading guilty in exchange for a 12-year sentence” demonstrates, at
the very least, an ambiguity in the plea agreement. Thus, appellant argues that because
he “understood he was pleading guilty in exchange for a 12-year sentence,” his “sentence
[should] be reduced to that term.”
We disagree. Throughout the course of the proceedings, appellant made only two
references to a 12-year sentence, with the second reference occurring at sentencing.
Appellant’s only other reference to a 12-year sentence occurred at a pretrial hearing on
January 15, 2015. But three days earlier, at a January 12, 2015 pretrial hearing, the
prosecutor read the state’s plea offer on the record:
the offer is to plead guilty to Count II, Unintentional Second Degree Murder, to be sentenced at the middle of the box and to dismiss Count I at sentencing, which is the Intentional Second Degree Murder count. With respect to today’s proceedings . . . the state has filed a notice of intent to seek an enhanced sentence in the event of a conviction based on the very serious aggravating factors that appear in this case. And I would expect at sentencing to be asking for the high end of the box and applying a multiplier at the time.
3 At the time the plea offer was read onto the record on January 12, the parties were
uncertain whether appellant had four or five criminal-history points. The plea agreement
was based on a criminal-history score of four, which under the sentencing guidelines
carried a presumptive “middle-of-the-box” sentence of 210 months. Appellant’s time
served under a 210-month sentence would have been approximately 12 years. See Minn.
Stat. § 244.101, subd. 1. Thus, appellant’s claimed ambiguity was based on his
misinterpretation of an accurate statement setting forth the plea offer.
Moreover, the record reflects that the plea offer was confirmed at the January 15
pretrial hearing. At that hearing, the offer was accurately clarified to be “225 months in
custody” based on a “middle of the box” sentence stemming from appellant’s criminal-
history score. The plea offer was then further clarified at the January 20, 2015 hearing.
Throughout these proceedings, appellant had ample time to discuss the offer with
counsel, and the record reflects that both the district court and the prosecutor were careful
not to proceed with a guilty plea until appellant had sufficient time to discuss his options
with counsel.
Finally, the record reflects that at appellant’s plea hearing advisory counsel stated
on the record that appellant would “plead guilty to Count II and . . . be sentenced in the
middle of the box.” Appellant then answered “[y]es” when asked if he understood that
“the only agreement we have is that you’ll plead guilty to Count II, which is
Unintentional Murder during the Commission of a Felony, and that you will be sentenced
to the middle of the box. Do you understand what that means?” Appellant also agreed
that he had “gone through the Minnesota Sentencing Guidelines Worksheet” with his
4 attorney, and that he understood what his presumptive sentence would be. The district
court found that “the facts offered in support of your plea constitute sufficient evidence to
support a jury verdict of guilty and that the plea you are making this morning is
voluntary, it’s knowing, it’s after having a substantial opportunity to confer with”
counsel. When viewed in its entirety, the record reveals no ambiguity in the plea
agreement, but rather that throughout the proceedings, the state’s plea agreement was for
a “middle-of-the-box” guidelines sentence in exchange for appellant’s plea of guilty to
second-degree unintentional murder. Therefore, the record does not support appellant’s
claim that he is entitled to a 12-year sentence due to an ambiguity in the plea agreement.
Affirmed.
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State of Minnesota v. William James Chestnut, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-minnesota-v-william-james-chestnut-minnctapp-2016.