Minter-King v. The State

Summary

The Georgia Court of Appeals reversed the denial of Mikai Minter-King’s motion to enforce a plea agreement. The court held that the written agreement, which Minter-King accepted and which required truthful testimony but did not require a formal proffer, contained agreement on the essential terms and was enforceable. The agreement remained binding despite the replacement of the prosecutor who negotiated it.

Holdings

1. A written plea agreement is enforceable when the parties have agreed on its essential terms, even if they have not agreed on a nonessential term such as the form or scope of a proffer. Because the State's written offer required truthful testimony but did not require a formal proffer, and Minter-King accepted the offer, the parties formed an enforceable agreement.
2. A valid and enforceable plea agreement is generally binding on successive prosecutors and cannot be unilaterally altered by a new prosecutor.

Questions Presented

1. Whether the parties formed an enforceable plea agreement when the State made a written offer requiring truthful testimony but not a formal proffer, and Minter-King accepted that offer.
2. Whether a successor prosecutor could refuse to enforce the accepted plea agreement by adding an on-the-record proffer requirement.
3. Whether the absence of agreement regarding the scope or form of a proffer rendered the plea agreement unenforceable.

Disposition

reversed