Espinoza v. Martin

In Espinoza v. Martin, 182 Ariz. 145, 147, 894 P.2d 688, 690 (1995), the Arizona Supreme Court considered whether a policy adopted by superior court judges summarily rejecting all plea agreements containing stipulated sentences violated Rule 17.4. 182 Ariz. at 146, 894 P.2d at 689. The supreme court determined that it did violate the rule. In its analysis, the Espinoza court interpreted Rule 17.4 as "guaranteeing the parties the right to present their negotiated agreement to a judge, to have the judge consider the merits of that agreement in light of the circumstances of the case, and to have the judge exercise his or her discretion with regard to the agreement." Id. at 147, 894 P.2d at 690. Ultimately, in ruling that "groups of judges may not implement policies to automatically reject all such plea agreements," the Espinoza court held that individual trial judges are required to give "individualized consideration" to plea agreements before accepting or rejecting them. Id. at 148, 894 P.2d at 693. The court articulated that in making its determination, the trial court must "review the plea agreement to see if the ends of justice and the protection of the public are being served by such agreement." Id. at 147, 894 P.2d at 692. The Arizona Supreme Court determined that a superior court policy to summarily reject all plea agreements that contained stipulated sentences violated Rule 17.4. 182 Ariz. at 146, 894 P.2d at 689. In its analysis, the court interpreted Rule 17.4 as "guaranteeing the parties the right to present their negotiated agreement to a judge, to have the judge consider the merits of that agreement in light of the circumstances of the case, and to have the judge exercise his or her discretion with regard to the agreement." Id. at 147, 894 P.2d at 690. Trial judges are required to give "individualized consideration" to plea agreements before accepting or rejecting them. Id. at 148, 894 P.2d at 691. The supreme court held that the trial judge must "review the plea agreement to see if the ends of justice and the protection of the public are being served by such agreement." Id. at 147, 894 P.2d at 690.