State v. Molina
State v. Molina, 2024 UT App 172 (Christiansen Forster, J.)
Criminal
The State offered Defendant a plea deal but later rescinded the offer. Defendant sought to enforce agreement, and the district court ordered specific performance. The Utah Court of Appeals reversed, holding:
- The district court incorrectly concluded that Defendant detrimentally relied on the State’s offer.
- Practice tip: Detrimental reliance in a plea deal requires showing that a witness is no longer available, as well as explaining who the witness was, what the testimony would have been, why the testimony could not be obtained from another source, and how the lack of testimony would adversely affect the defense.
- Judicial tip: Decisions of whether to enforce a plea agreement and whether a defendant detrimentally relied on a plea agreement are both reviewed for correctness.