This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant entered into a plea and disposition agreement with the State, pleading guilty to possession of methamphetamine, two misdemeanors, and admitting to being a habitual offender based on three prior felonies. The agreement stipulated a three-year prison sentence followed by one year of parole, with an eight-year habitual offender enhancement withheld unless the Defendant committed a drug, theft, or felony offense during parole. The Defendant violated several parole conditions but did not commit any new crimes (paras 2-3, 9).
Procedural History
- District Court, January 31, 2003: The trial court dismissed the State's petition to impose the eight-year habitual offender enhancement, finding it lacked jurisdiction as the Defendant had completed his sentence and parole (para 6).
Parties' Submissions
- Appellant (State): Argued that the trial court had jurisdiction to impose the enhanced sentence because the Defendant was adjudged a habitual offender during the original sentencing. The State contended that the Defendant violated the plea agreement by admitting to parole violations, and the issuance of a bench warrant before parole expiration demonstrated intent to maintain jurisdiction (paras 5-6, 8).
- Appellee (Defendant): Asserted that the trial court lacked jurisdiction to impose the enhanced sentence as the Defendant had fully served his sentence and parole. The Defendant argued that the parole violations did not constitute a breach of the plea agreement, as no new drug, theft, or felony offenses were committed (paras 5, 9-10).
Legal Issues
- Did the trial court lack jurisdiction to impose the eight-year habitual offender enhancement after the Defendant completed his sentence and parole?
- Did the Defendant's parole violations constitute a breach of the plea and disposition agreement?
Disposition
- The Court of Appeals affirmed the trial court's dismissal of the State's petition to impose the eight-year habitual offender enhancement (para 12).
Reasons
Per Vigil J. (Alarid and Bustamante JJ. concurring):
The Court held that the plea and disposition agreement was a binding contract, and its terms must be interpreted according to contract principles. The agreement stipulated that the Defendant would be subject to the eight-year enhancement only if he committed a drug, theft, or felony offense during parole. The Defendant's parole violations, including a positive drug test, did not constitute criminal offenses under the agreement. The Court emphasized that the State could have included broader terms in the agreement but did not. Since no new crimes were committed, the Defendant did not breach the agreement, and the trial court correctly dismissed the State's petition for lack of jurisdiction (paras 7-11).