Coy v. Fields

In Coy v. Fields, 200 Ariz. 442, P 9, 27 P.3d 799, 802 (App. 2001), in accordance with the terms of a plea agreement, the trial court imposed a probationary term far in excess of the term statutorily authorized for the offenses to which the defendant had pled. Coy, 200 Ariz. 442, P 3, 27 P.3d at 800. After sentencing, the defendant filed a motion to modify the probationary term. Id. The state responded by requesting permission to withdraw from the plea agreement and the trial court granted the state's request. Id. The defendant sought special action relief in this court. Applying contract principles, we found that the state, as the party "'in the better position to know the correct law,'" bore the risk of any mistake in the plea agreement. Id. PP 12-13, quoting State v. Patience, 944 P.2d 381, 388 (Utah App. 1997). The Court also found that nullifying the probation provision would not materially alter the agreement, "which provided only for the possibility of up to lifetime probation" and did not require the imposition of any probationary term. Id. P 10. The Court therefore concluded there was "no valid ground on which the state was entitled to withdraw from the plea agreement" and directed the trial court to impose an appropriate sentence. Id. P 13.