Arizona Supreme Court: State of Arizona v. Bennet Laquan Williams
Case No. CR-23-0068-PR, Filed August 6, 2024
ISSUES:
1. Whether a plea agreement becomes void when a prior conviction used as a sentence enhancement is expunged due to a change in law.
2. Whether the State can unilaterally allege a different prior conviction to enhance the sentence under an existing plea agreement.
DECISION:
1. The plea agreement is not automatically void but becomes voidable if the defendant is resentenced to a term different from what was agreed upon in the plea agreement.
2. The State cannot unilaterally allege a different prior conviction under the existing plea agreement, as it would change a material term of the agreement.
Synopsis:
Williams accepted a plea agreement of guilty to two counts of sex trafficking as a repeat offender based on a prior marijuana conviction. After the passage of Proposition 207 (the Smart and Safe Arizona Act), Williams successfully expunged his marijuana conviction and sought post-conviction relief. The Court held that when a defendant successfully challenges a previously accepted guilty plea due to a change in the plea’s factual basis, the underlying plea agreement becomes voidable if the defendant is subsequently resentenced to a term different from what was originally agreed upon. The Court emphasized that the plea agreement is not automatically void, as the Court of Appeals stated, but becomes voidable at the election of the frustrated party.
NOTE: The Court also addressed the application of contract law principles to plea agreements, adopting a four-part test for frustration of purpose from the Restatement (Second) of Contracts.
Outcome of the Case:
The Arizona Supreme Court vacated paragraphs 14 through 17 of the Court of Appeals’ opinion, affirmed the remainder of the opinion, reversed the trial court’s post-conviction relief order, and remanded the case to the trial court for resentencing. The Court ruled that if Williams is resentenced to less than the agreed-upon twelve years, the State may withdraw from the agreement. Conversely, if Williams is resentenced to more than twelve years, he may withdraw his plea. If either party withdraws from the plea agreement, the State may reinstate the original charges and allege Williams’s prior convictions.