United States v. Lay

10 M.J. 678, 1981 CMR LEXIS 834
CourtU.S. Army Court of Military Review
DecidedJanuary 8, 1981
DocketSPCM 14586
StatusPublished

This text of 10 M.J. 678 (United States v. Lay) is published on Counsel Stack Legal Research, covering U.S. Army Court of Military Review primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Lay, 10 M.J. 678, 1981 CMR LEXIS 834 (usarmymilrev 1981).

Opinions

OPINION OF THE COURT

CLAUSE, Judge:

In accordance with his pleas of guilty, the appellant was convicted by a military judge, sitting as a special court-martial, of two violations of Article 130, two violations of Article 121, one violation of Article 109, one violation of Article 80, and four violations of Article 92, Uniform Code of Military Justice, 10 U.S.C. §§ 930, 921, 909, 880, 892. He was sentenced to a bad-conduct discharge, confinement at hard labor for three months, forfeiture of $290.00 pay per month for six months, and reduction to the grade of Private E-l. The convening authority approved the findings and sentence.

Appellant’s pleas of guilty were entered pursuant to a pretrial agreement. The military judge conducted a full and complete Care providency inquiry. However, in discussing the pretrial agreement with the appellant, he did not address each of the provisions contained therein. Specifically, he omitted the routine cancellation clauses, which included a “subsequent misconduct” provision. Appellant now asserts that his pleas must be held improvident because of the failure of the military judge to assure on the record that he understood the meaning and effect of each condition of the pretrial agreement.

The question is not whether the military judge followed the best course in conducting his inquiry, or even whether he literally followed the guidance of King and Green, but whether his inquiry fell below the standard for determining providence. I think not.

A military judge has the “primary responsibility for assuring on the record that an accused understands the meaning and effect of each condition as well as the sentence limitations imposed by any existing pretrial agreement.” In addition he “should secure from counsel for the accused as well as the prosecutor their assurance that the written agreement encompasses all of the understandings of the parties and [680]*680that the judge’s interpretation of the agreement comports with their understanding of the meaning and effect of the plea bargain.” These requirements were set forth in United States v. Elmore, 1 M.J. 262, 264 (CMA 1976), by Judge Fletcher in his concurring opinion and made mandatory in United States v. Green, 1 M.J. 453 (CMA 1976). United States v. King, 3 M.J. 458 (CMA 1977), decided that mere substantial compliance with these requirements was not sufficient.

Although the Court of Military Appeals stated in King that substantial compliance with the Green requirements for conducting an inquiry into the pretrial agreement was not sufficient, the question remains where the line should be drawn between literal compliance and substantial compliance. In a footnote in its recent decision in United States v. Cruz, 10 M.J. 32 (CMA 1980), the Court of Military Appeals stated that since all the terms of the pretrial agreement in that case were mutually understood, the question of whether “strict or substantial” compliance with the King-Green mandate was necessary need not delay them. The Court of Military Appeals has numerous cases pending before it, both on petitions granted and on certification, involving several aspects of the adequacy of the Green inquiry. Also included is the specific issue involved in this case. United States v. Crawford, certificate for review filed, 9 M.J. 269. The previous action on petitions filed with the Court involving the Green issue has not clarified the issue. See, Lause, “Crowley: The Green Inquiry Lost in Appellate Limbo,” The Army Lawyer (DA Pam. 27-50-77), May 1979. It is in this light that we must decide the present issue.

Pleas of guilty have long been an important part of civilian and military criminal law and account for the disposition of most criminal cases. The fact that most of these pleas were the result of negotiation between the government and the accused was not judicially noted until more recent times. The Supreme Court stated in Santobello v. New York, 404 U.S. 257, 92 S.Ct. 495, 30 L.Ed.2d 427 (1971), that “the disposition of criminal charges by agreement between the prosecutor and the accused, sometimes loosely called ‘plea bargaining,’ is an essential component of the administration of justice. Properly administered, it is to be encouraged.” What has been insisted on is that pleas of guilty be voluntary. For some time, only advice in open court as to the defendant’s important constitutional rights and the establishment of a factual basis for the plea was required. More recently, the courts began to encourage the disclosure in open court of plea bargain agreements. In United States v. Williams, 407 F.2d 940, 949 (4th Cir. 1969), it was pointed out that “such disclosure would enable the trial judge to exercise a proper controlling influence and to reject any such arrangements he deemed unfair either to the defendant or to the public.” Similarly, in Jones v. United States, 423 F.2d 252 (9th Cir. 1970), the court aptly stated:

Full disclosure reduces the risk of an unfair agreement — unfair to the public because of an unwarranted concession by an overburdened prosecutor anxious to avoid trial; or unfair to the defendant because the concession is either illusory, or, at the other extreme, so irresistible in light of the inevitable risk of trial as to induce an innocent defendant to plead guilty. Airing plea agreements in open court enhances public confidence in the administration of justice. Covert bargains excite suspicion; and arrangements in which palpably false answers to ritualistic questions are solemnly recorded reflect adversely upon all who participate.

A disclosure requirement has now been incorporated in most if not all criminal jurisdictions, either by judicial decree or by statutory rules of criminal procedure. It is clear that the underlying purpose of these rules, whatever their format, is to expose to judicial and public scrutiny all pretrial agreements. See, section 1.5 “Determining Voluntariness of Plea,” ABA Standards Relating to Pleas of Guilty. Most jurisdictions require that the agreement be orally disclosed in open court; however, a few, including the military, have required or fol[681]*681lowed a practice that pretrial agreements be reduced to writing. This distinction is important when one considers the consequences of a failure to follow the prescribed procedure for making the agreement a matter of record. This distinction must be considered when reviewing state and federal decisions which rely only on an oral disclosure. Where the written agreement is entered into the record and all parties agree that it contains all of the agreements between the parties, the primary purposes of disclosure have been satisfied. A review of the standards of other jurisdictions for determining providence is helpful.

Arizona is a state where the pretrial agreement is placed in writing and introduced into the record. In State v. Salas, 23 Ariz.App. 297, 532 P.2d 872

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Related

Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
Santobello v. New York
404 U.S. 257 (Supreme Court, 1971)
United States v. Timmreck
441 U.S. 780 (Supreme Court, 1979)
United States v. William Dove Williams
407 F.2d 940 (Fourth Circuit, 1969)
William E. Jones v. United States
423 F.2d 252 (Ninth Circuit, 1970)
Lee Jackson Keel v. United States
585 F.2d 110 (Fifth Circuit, 1978)
United States v. Winston Eugene Dayton
604 F.2d 931 (Fifth Circuit, 1979)
State v. Salas
532 P.2d 872 (Court of Appeals of Arizona, 1975)
State v. Mendiola
532 P.2d 193 (Court of Appeals of Arizona, 1975)
In Re Guilty Plea Cases
235 N.W.2d 132 (Michigan Supreme Court, 1975)
People v. Shekoski
224 N.W.2d 656 (Michigan Supreme Court, 1974)
Williams v. State
522 S.W.2d 488 (Court of Criminal Appeals of Texas, 1975)
Guster v. State
522 S.W.2d 494 (Court of Criminal Appeals of Texas, 1975)
United States v. Elmore
1 M.J. 262 (United States Court of Military Appeals, 1976)
United States v. Green
1 M.J. 453 (United States Court of Military Appeals, 1976)
United States v. King
3 M.J. 458 (United States Court of Military Appeals, 1977)
United States v. Harrison
5 M.J. 687 (U S Air Force Court of Military Review, 1978)
United States v. Hendon
6 M.J. 171 (United States Court of Military Appeals, 1979)
United States v. Thomas
6 M.J. 573 (U.S. Army Court of Military Review, 1978)

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10 M.J. 678, 1981 CMR LEXIS 834, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-lay-usarmymilrev-1981.