Plea, Rejection of
Except as indicated, all indented material is copied directly from the court’s opinion.
Decisions of the Tennessee Supreme Court
Decisions of the Tennessee Court of Criminal Appeals
State v. Lawson, No. E2021-00664-CCA-R3-CD, p. 6-7 (Tenn. Ct. Crim. App. Aug. 23, 2022).
The decision to accept or reject a plea agreement lies within the trial court’s discretion. State v. Hawkins, 519 S.W.3d 1, 40 (Tenn. 2017); see Tenn. R. Crim. P. 11(c)(3), (4), (5). A trial court abuses its discretion when it applies an incorrect legal standard or reaches a conclusion that is illogical or unreasonable and causes an injustice to the complaining party. Hawkins, 519 S.W.3d at 40. In considering the plea, the court must determine if the plea agreement is helpful in the administration of justice and is in the best interest of the public. State v. Williams, 851 S.W.2d 828, 831 (Tenn. Crim. App. 1992). “The court is not obligated to accept any agreement, but if the agreement is to a specific sentence, the court must give the defendant an opportunity to withdraw the plea if the agreement is not accepted.” VanArsdall v. State, 919 S.W.2d 626, 629 (Tenn. Crim. App. 1995); see Tenn. R. Crim. P. 11(c). The trial court is taxed with the ultimate decision to accept or reject a plea bargain, and a plea agreement has no force prior to its acceptance by the court. State v. Turner, 713 S.W.2d 327, 329 (Tenn. Crim. App. 1986). The discretion of the trial court in rejecting a plea agreement is not absolute, however. Williams, 851 S.W.2d at 832. A trial court’s discretion must be guided by sound legal principles. Hawkins, 519 S.W.3d at 40. “That there is discretion at all implies that there are limits to its exercise. It must not be arbitrary.” Williams, 851 S.W.2d at 832. For example, blanket policy of rejecting plea agreements in which the defendant does not acknowledge guilt may be an abuse of discretion. Id. Rejection of a plea agreement based on an error of law is also an abuse of discretion. Goosby v. State, 917 S.W.2d 700, 706-07 (Tenn. Crim. App. 1995) (the trial court abused its discretion when it rejected the plea agreement based on a mistaken belief that it could not sever the defendant and codefendant’s trial).
