WASHINGTON (CN) – No precedent required a lighter sentence for a man whose charges were compounded after he had already negotiated a plea deal, the U.S. Supreme Court ruled Monday.
California brought its complaint against Michael Cuero in October 2005, about two weeks after Cuero drove his car into a man standing outside of his parked pickup truck.
In addition to having been driving without a license, high on methamphetamine, Cuero was on parole and carrying a loaded 9-millimeter semiautomatic pistol.
Cuero pleaded guilty that December to two of the charges against him – causing bodily injury while driving under the influence of a drug and unlawful possession of a firearm.
The plea carried a maximum sentence of about 14 years in state prison, but California prosecutors requested permission to amend the criminal complaint before Cuero’s scheduled sentencing date of Jan. 11, 2006.
Whereas the plea represented one of Cuero's four prior convictions as a predicate offense under California’s “three strikes” law, prosecutors determined that Cuero actually had two prior strikes – residential burglary and assault with a deadly weapon.
This second strike meant that Cuero faced a minimum punishment of 25 years. The trial court granted the motion and allowed Cuero to withdraw his guilty plea so as to return parties to the status quo.
After Cuero entered a new plea, he was sentenced to the stipulated term of 25 years to life in prison.
Cuero exhausted his post-conviction remedies until the Ninth Circuit held last year that the trial court’s refusal to enforce the original plea agreement violated clearly established precedent.
California appealed and the Supreme Court summarily reversed Monday, finding nothing in its past cases demanding specific performance as a remedy for constitutional violations.
“To the contrary, no ‘holding of this court’ requires the remedy of specific performance under the circumstances present here,” the unsigned opinion states.
Later the 8-page ruling continues: “Where, as here, none of our prior decisions clearly entitles Cuero to the relief he seeks, the “state court’s decision could not be ‘contrary to’ any holding from this court.”
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