Michigan v. Guyton (Opinion on Application - Remand to TC)
Annotate this CaseDefendant Candace Guyton pled guilty to one count of armed robbery. As part of the plea deal, the prosecution agreed not to pursue charges against defendant in an unrelated case and to recommend a sentence within the guidelines minimum range of 51 to 85 months in prison. The prosecutor also agreed to dismiss the supplemental information charging defendant as a third-offense habitual offender. However, the amended felony information wrongly classified defendant as a third-felony offender by counting a single prior conviction twice; in fact, defendant was eligible to be charged only as a second-offense habitual offender. The trial court sentenced defendant at the top of the agreed-upon guidelines range to 84 months to 60 years in prison. Defendant later moved to withdraw her plea, arguing that it was involuntary and unknowing given that defendant was told she was avoiding a third-offense habitual-offender enhancement. The trial court denied the motion, agreeing with the prosecution that defendant had received benefit from the plea despite the error. The Court of Appeals affirmed the trial court’s denial of defendant’s motion. After its review, the Michigan Supreme Court determined the misinformation regarding defendant’s habitual-offender enhancement rendered defendant’s guilty plea involuntary and unknowing. Accordingly, the case had to be remanded to the trial court to give defendant the opportunity to elect to allow her plea to stand or withdraw her plea.
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