Georgia v. LewisAnnotate this Case
After a grand jury indicted defendant Crawford Lewis, Patricia Reid and Anthony Pope, on charges of violating Georgia’s Racketeer Influenced and Corrupt Organizations (RICO) Act and felony theft by taking, the State offered Lewis a plea deal. In exchange for pleading guilty to one misdemeanor count of hindering and obstructing a law enforcement officer, the State agreed to dismiss the RICO and related theft charges against Lewis, conditioned upon his testifying truthfully at the trial of his co-defendants. At the time his plea was entered, Lewis understood that if he satisfied his obligations with respect to providing truthful testimony against his co-defendants, the State would recommend to the trial court that he be sentenced to 12 months' probation, a fine, and community service. The trial court accepted Lewis’ plea, but withheld sentencing pending Lewis’ compliance with the plea terms and a final resolution in the case against his codefendants. At his sentencing hearing, the State proffered that Lewis had complied with the conditions of the plea bargain by testifying truthfully, and asked the trial court to impose the agreed upon sentence. Without specifically addressing the question of whether Lewis’ trial testimony had been truthful, the trial court rejected the State’s sentencing recommendation and announced its intention to sentence Lewis to 12 months to serve. The trial court then gave Lewis an opportunity to withdraw his plea and proceed to trial, but he chose not to do so. The Georgia Supreme Court granted a petition for writ of certiorari in this case to decide, inter alia, whether the Court of Appeals erred in determining that a trial court, having agreed to accept the terms of a negotiated plea agreement between the State and Lewis, retained the authority to decide whether the terms of the plea agreement had been satisfied and reject the plea agreement if they had not. The State contended that having agreed to accept the terms of a plea bargain the State negotiated with Lewis, the trial court subsequently lacked the authority to determine whether the terms of the parties’ plea agreement had been fulfilled absent a dispute between the parties. The Supreme Court concluded that the Court of Appeals’ opinion properly balanced the rights of the parties with respect to the enforcement of the terms of a plea agreement with the power of the trial court to reject such agreements, and affirmed.