State v. Wheeler – Case Brief
State v. Wheeler, 631 P.2d 376 (Wash. 1981).
Facts: Wheeler (D) was offered a plea bargain which was withdrawn before Wheeler had the opportunity to accept and offer a guilty plea. Wheeler sought specific performance of prosecutor’s plea bargain offer. Wheeler contended that the prosecutor could not rescind the offer before Wheeler had an opportunity to accept it.
Issue: May a prosecutor withdraw a plea agreement before the entry of the defendant’s guilty plea?
Holding and Rule: Yes. Absent detrimental reliance, a prosecutor may withdraw a plea agreement prior to the actual entry of the defendant’s guilty plea. Most jurisdictions apply strict contract principles to plea bargain agreements. The court held that a plea agreement is a unilateral contract and only the defendant’s plea, or some other detrimental reliance, can constitute an acceptance. There court held that there was no right to the opportunity for a plea bargain under the constitution.