Brief Fact Summary. A prosecutor offered defendant George Johnson a plea deal and then when defendant’s attorney notified the prosecutor they would accept the deal, the prosecutor withdrew it and offered a substantially less appealing deal.
Synopsis of Rule of Law. A criminal defendant’s acceptance of a prosecutor’s proposed plea bargain does not create a constitutional right to its enforcement.
The Due Process Clause is not a code of ethics for prosecutors; its concern is with the manner in which persons are deprived of their liberty.View Full Point of Law
Issue. If a criminal defendant accepts a prosecutor’s proposed plea deal, are they constitutionally protected from having that offer subsequently withdrawn?
Held. No. Reverse the Court of Appeals.
A criminal defendant is not constitutionally protected from having a plea deal that they accept from being withdrawn. The respondent’s plea was not induced by the withdrawn offer, and therefore it did not affect the voluntariness of his plea. As a result, there is no Fourteenth Amendment claim.
Discussion. A unanimous court agreed as a baseline that a voluntary plea of guilty by an accused person advised by competent counsel cannot be collaterally attacked and viewed this defendant under these facts as not deserving any different treatment just because the prosecutor may have misleading. They wanted this plea to stand regardless of whether the prosecutor was guilty of any ethical violations.