State v. Rahab

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Defendant was charged with burglary. Before Defendant’s trial was to begin, the court confirmed that Defendant had been offered and rejected a plea offer. After a jury trial, Defendant was found guilty. Following a sentencing hearing, the court imposed a six-year term of imprisonment. Defendant appealed, arguing that the trial court vindictively imposed a sentence in retaliation for the exercise of his right to a jury trial in violation of his due process rights. The court of appeals affirmed. The Supreme Court affirmed, holding (1) there is no presumption of vindictiveness when, after trial, a court sentences a defendant to a longer term than was offered by the state in plea negotiations; (2) an appellate court may reverse a sentence for vindictiveness only if, upon its examination of the entire record, it clearly and convincingly finds the sentence was based on actual vindictiveness; and (3) applying this standard, the trial court did not vindictively sentence Defendant. View "State v. Rahab" on Justia Law