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Guilty Pleas – Withdrawal of Plea — Post-sentencing — Coercion – Grounds: “Package” Agreement, Youthfulness of Defendant

State v. Timothy J. Goyette, 2006 WI App 178
For Goyette: E.J. Hunt, Kathleen M. Quinn

Issue: Whether Goyette was coerced into pleading guilty under a “package” agreement (one “contingent on two or more codefendants all entering pleas according to the terms of the agreement”), given the seriousness of the charges and the youthfulness (age 16) of the defendant.

Holding: In the absence of any evidence that Goyette was too young to understand the implications or that he was pressured by his attorney or unable to meet alone with him, the trial court finding of no coercion is unassailable, ¶¶23-26. Nor did the offer of a package deal pressurize him in such a way as to amount to illicit coercion:

¶31 Collectively, Craker, Seybold, and Drake reject the proposition that a plea is constitutionally involuntary if it is motivated by a desire to obtain a benefit for another. None of these cases involved a package plea agreement, but Goyette suggests no reason why their reasoning should not apply here. We agree with Goyette that package plea agreements carry with them the risk that one of the defendants will be improperly pressured into entering a plea. But the pressure Goyette describes is not improper pressure. It is the same type of self-imposed pressure at issue in Craker, Seybold, and Drake.¶32 Therefore, we agree with the State that, even if the package plea agreement’s offer of reduced charges, carrying with it limited exposure to imprisonment, had no effect on Goyette’s decision to plead guilty and that Goyette only entered his pleas to help his friends, such facts would not establish that Goyette’s pleas were involuntary.

The court declines to reach the question of whether a package plea agreement is necessarily invalid, or whether such an agreement requires that “plea hearings be held individually for each defendant,” ¶24, n. 13.

 

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