People v. Samuels

Brief Filed: 12/23
Court: Supreme Court of Michigan
Year of Decision: 2024

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Whether a trial court is required to hold an evidentiary hearing on the voluntariness of a guilty plea that is induced in part by an offer of leniency to a relative, and if so, how a trial court is to determine whether an offer of leniency to a relative “rendered the defendant’s plea involuntary in fact.

False Confessions

The defendant Dwight Samuels and his identical twin brother Duane were charged with various felonies for fighting and shooting Mr. Keith Flye in a restaurant. The defendant pleaded guilty to assault with intent to commit murder (AWIM), and possession of a firearm during the commission of a felony (felony-firearm), second offense. At sentencing, the defendant moved to withdraw his guilty plea and asked to go to trial because his plea was involuntary, at least in part because both brothers were required to plead guilty in order for either one to do so. The trial court denied the defendant’s motion without holding an evidentiary hearing on the matter of involuntariness and sentenced him to 13 to 30 years’ imprisonment for the AWIM conviction and five years’ consecutive imprisonment for the felony-firearm conviction, as contemplated by the plea offer. The Michigan Court of Appeals (the mid-level appellate court) affirmed the trial court’s decision. The defendant may be a vulnerable adult, as he has limited literacy, an eighth-grade education, no employment history, and was supported by Social Security Disability Benefits. The defendant had voiced his protest about the plea offer until his brother’s attorney stated that the brother’s plea would be accepted, defendant knew that his brother had lost significant weight during his time in jail, and defendant’s family members were in the audience.

APA’s brief provides psychological science demonstrating the coercive influence of tie-barring guilty pleas, particularly how leniency towards a family member may coerce the acceptance of a plea offer. The brief also provides psychological science about the intense ties between twins, as the defendant and his brother are twins.

On July 12, 2024, by a 5-2 vote, the court held that if a defendant seeks to withdraw his guilty plea as involuntary and the record reveals a factual question about the voluntariness of a “package-deal” plea, the trial court must hold an evidentiary hearing to determine whether, considering all the circumstances, the plea was involuntary. The court further held that there was such a fact question here so an evidentiary hearing was required (contrary to the court of appeals’ ruling).

The court did not cite our amicus brief, but its decision and reasoning is fully consistent with our arguments. The court stated at one point, for example, that (as our brief explained) “[p]sychological pressures sufficient to indicate an involuntary plea might be present if the third party promised leniency is a close friend or family member whom the defendant feels compelled to help.”