State v. Lambert

2001 ME 113, 775 A.2d 1140, 12 A.L.R. 6th 853, 2001 Me. LEXIS 115
CourtSupreme Judicial Court of Maine
DecidedJuly 19, 2001
StatusPublished
Cited by6 cases

This text of 2001 ME 113 (State v. Lambert) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Lambert, 2001 ME 113, 775 A.2d 1140, 12 A.L.R. 6th 853, 2001 Me. LEXIS 115 (Me. 2001).

Opinion

DANA, J.

[¶ 1] Donald Lambert appeals from the judgment of the Superior Court (Penob-scot County, Mead, C.J.) denying his motion to withdraw his nolo contendere plea to the charge of arson (Class A), 17-A M.R.S.A. § 802 (1983 & Supp.2000), 1 and his guilty plea to the charge of burglary (Class C), 17-A M.R.S.A. § 401 (1983). 2 Lambert contends that the Superior Court abused its discretion; we disagree and affirm.

BACKGROUND

[¶ 2] Lambert was indicted on four counts, including arson (Class A), 17-A M.R.S.A. § 802 and burglary (Class C), 17-A M.R.S.A. § 401. At the Rule 11 3 proceeding on June 13, 2000, Lambert pleaded nolo contendere to the arson charge, which the State indicated was based on accomplice liability, 4 and guilty to the burglary charge. The pleas were entered pursuant to an agreement in which the State agreed to dismiss the remaining counts and to request a stay of sentencing until September. Lambert acknowledged “his involvement and participation in the underlying burglary ... of merchandise, but certainly disputefd] ... any direct participation in the fire that was set....” The court accepted the pleas, finding that there was “a sufficient basis upon which a fact finder could find the defendant guilty beyond a reasonable doubt,” and stayed the sentencing until September.

[¶ 3] On September 15, 2000, Lambert moved to withdraw his pleas on the basis *1142 that he had “no direct involvement in and disputes the State’s accomplice liability theory” on the arson charge. At the hearing on the motion to withdraw, the State contended that: a substantial amount of time had passed between Lambert’s pleas and his motion to withdraw, it would be prejudiced by the withdrawal of the pleas because the victims and a key witness were living out of state and it would be a hardship on the victims and difficult for the State to force the victims and the key witness back to Maine for a trial, and Lambert’s desire to withdraw his pleas was a tactical decision. After evaluating three of the four factors articulated in State v. Hillman, 2000 ME 71, ¶ 8, 749 A.2d 758, 761, the court denied the motion. Pursuant to the plea agreement, the remaining two counts were dismissed, and Lambert was sentenced. 5 This appeal followed.

DISCUSSION

[¶ 4] “A motion to -withdraw a plea of guilty or of nolo contendere may be made only before sentence is imposed.” M.R.Crim.P. 32(d). “Although relief should be granted liberally, a defendant does not have an absolute right to withdraw a plea.” Hillman, ¶ 7, 749 A.2d at 760.

[¶ 5] The denial of a motion to withdraw a plea is reviewed for an abuse of discretion. Id. We evaluate four factors when reviewing the trial court’s exercise of its discretion in denying a motion to withdraw: (1) “The length of time between entering the plea and seeking to withdraw it”; (2) “The potential prejudice to the State”; (3) “The defendant’s assertions of innocence”; and (4) “Any deficiency in the proceeding at which the defendant entered the plea in accordance with M.R.Crim.P. 11.” Id. ¶ 8, 749 A.2d at 761.

[¶ 6] The pleas were entered on June 13, 2000, and Lambert moved to withdraw the pleas on September 15, 2000, the day set for his sentencing hearing. Thus, three months had elapsed between entering the plea and seeking to withdraw it. See United States v. Daniels, 821 F.2d 76, 79 (1st Cir.1987) (indicating that waiting ten weeks between entering a plea and withdrawing it was a lengthy period of time); United States v. Barker, 514 F.2d 208, 222 (D.C.Cir.1975) (“A swift change of heart is itself strong indication that the plea was entered in haste and confusion .... ”).

At the motion hearing, the State argued and the court determined that there was potential prejudice to the State because the central witnesses to the State’s case had moved out of state and “that carries with it the attendant uncertainty and almost presumed difficulty in getting them back here.”

[¶ 8] The court primarily focused on the third factor, the credibility of Lambert’s assertion of innocence. Lambert contends that although he acknowledged his involvement in the underlying burglary, he “consistently denied any involvement with setting a fire and denied the arson charge.” In contrast to the Rule 11 hearing, in which he acknowledged that “the State [had] sufficient evidence, which if believed, could form the basis of a conviction,” Lambert now claims that “a jury would likely acquit.”

[¶ 9] The mere presence of the assertion of innocence “does not necessarily entitle a defendant to withdraw his plea *1143 of guilty.” Hillman, ¶ 12, 749 A.2d at 761. Similarly, when a defendant pleads nolo contendere “and thus did not explicitly admit his guilt, and where he did concede that he believed the State could convict him if the case went to trial, the fact that defendant consistently insisted on his legal innocence does not require that he be permitted to withdraw his nolo plea and go to trial.” State v. Pokorny, 458 A.2d 1212, 1217 (Me.1983). Moreover, “were mere assertion of legal innocence always a sufficient condition for withdrawal, withdrawal would effectively be an automatic right.” Hillman, ¶ 12, 749 A.2d at 762 (quoting Nunez Cordero v. United States, 533 F.2d 723, 726 (1st Cir.1976)).

[¶ 10] Although the court recognized that Lambert withdrew his pleas because he did not start the fire, the court noted that Lambert was not asserting innocence of the underlying crime or the fact that the fire did not occur in conjunction with the burglary. The court acknowledged that “liability for a crime can attach if there’s accomplice liability”; therefore, the court did not abuse its discretion in discounting the force of Lambert’s assertion of innocence.

[¶ 11] The court did not address the fourth factor concerning deficiencies in the Rule 11 proceeding because it was not aware of any. Lambert contends, for the first time on appeal, that the court erred at the Rule 11 hearing by failing to inform him of the difference between a nolo contendere plea and a guilty plea.

[¶ 12] Rule 11 hearings establish “a procedure to ensure that constitutional and procedural prerequisites are met before a guilty plea is accepted.” State v. Comer, 584 A.2d 638, 640 (Me.1990). “A plea is valid if it is made voluntarily with knowledge of the elements of the crime, the penalty that might be imposed and the constitutional rights relinquished by foregoing trial.” Id.;

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Bluebook (online)
2001 ME 113, 775 A.2d 1140, 12 A.L.R. 6th 853, 2001 Me. LEXIS 115, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lambert-me-2001.