State v. Manywhitehorses

Summary

The Supreme Court of Montana considered whether the prosecutor breached a plea agreement during sentencing by presenting evidence and recommending a 100-year sentence for negligent homicide. The court held that the plea agreement imposed no limitation on the State’s sentencing recommendation for negligent homicide and that the evidence presented was relevant to the defendant’s history and the offenses. The judgment was affirmed.

Holdings

1. A plea agreement is a contract subject to contract-law standards, and whether the prosecutor breached it is reviewed de novo.
2. The State did not breach the plea agreement because the agreement required only a recommendation of twenty years for tampering with physical evidence and imposed no sentencing recommendation limit for negligent homicide.
3. The State did not violate the plea agreement by presenting photographs and testimony that could suggest deliberate homicide because the evidence was also relevant to the defendant's history and to the offenses to which she pleaded guilty.

Questions Presented

1. Whether the prosecutor breached the State's contractual obligations under the plea agreement by presenting evidence and arguing for a 100-year sentence for negligent homicide at sentencing.

Disposition

affirmed