Mabry v. Johnson
467 U.S. 504 (1984)
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Rule of Law:
A defendant's acceptance of a prosecutor's proposed plea bargain does not create a constitutional right to have the bargain specifically enforced. The Due Process Clause is implicated only by the defendant's guilty plea itself, which must be voluntary and intelligent, not by the pre-plea negotiation process.
Facts:
- George Johnson was involved in a burglary during which a resident was killed and two others, including Johnson, were wounded.
- After Johnson's initial murder conviction was overturned by the Arkansas Supreme Court, plea negotiations began for the retrial.
- On October 27, 1972, a deputy prosecutor offered Johnson a deal: a guilty plea to accessory after a felony murder in exchange for a recommended 21-year sentence to be served concurrently with his existing sentences for burglary and assault.
- The next day, Johnson's attorney communicated Johnson's acceptance of the offer to the prosecutor.
- Two days later, the prosecutor informed Johnson's attorney that the offer was a mistake and withdrew it.
- The prosecutor then proposed a new offer: a 21-year sentence to be served consecutively to Johnson's existing sentences.
- Johnson initially rejected the second, less favorable offer and proceeded to trial.
- After the trial judge declared a mistrial, Johnson accepted the prosecutor's second offer and pleaded guilty.
Procedural Posture:
- After Johnson's initial murder conviction was reversed by the Arkansas Supreme Court, he pleaded guilty to accessory after a felony murder in an Arkansas state trial court based on a revised plea offer.
- After exhausting state remedies, Johnson filed a petition for a writ of habeas corpus in the U.S. District Court, arguing the state's withdrawal of its first plea offer was unconstitutional.
- The District Court dismissed the petition.
- Johnson, as appellant, appealed to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals, finding for Johnson, reversed the District Court's dismissal.
- Mabry, the Commissioner of the Arkansas Department of Correction, petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does a defendant's acceptance of a prosecutor's proposed plea bargain create a constitutional right to have the bargain specifically enforced after the prosecutor withdraws the offer?
Opinions:
Majority - Justice Stevens
No, a defendant's acceptance of a prosecutor's plea offer does not create a constitutional right to its enforcement. A plea bargain is merely an executory agreement with no constitutional significance until it is embodied in the judgment of a court. The constitutionality of a conviction based on a guilty plea depends on whether the plea itself was voluntary and intelligent. Here, Johnson's plea was not induced by the prosecutor's withdrawn offer; he pleaded guilty with full awareness that the prosecution would recommend a consecutive sentence, as per the second, operative offer. Unlike the defendant in Santobello v. New York, Johnson was not pleading guilty based on an unfulfilled promise. Because Johnson was fully aware of the consequences of his plea at the time he made it, the plea was voluntary and intelligent, and his inability to enforce the earlier, withdrawn offer is without constitutional significance. The prosecutor's potential negligence in making and withdrawing the initial offer is irrelevant, as the Due Process Clause is not a code of ethics but a protection against fundamentally unfair deprivations of liberty.
Analysis:
This decision clarifies that plea bargains do not attain constitutional protection analogous to contract law principles merely upon offer and acceptance. It firmly places the constitutional inquiry on the voluntariness of the actual guilty plea, not on the fairness of the preceding negotiations. By distinguishing Santobello, the Court narrowed the grounds for challenging a plea, giving prosecutors significant latitude to withdraw offers before a defendant has detrimentally relied on them by entering a plea. This holding reinforces the idea that until a plea is formally entered and accepted by a court, the process is fluid, and a defendant's constitutional rights are not violated by a withdrawn offer as long as the final plea is knowing and voluntary.
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