State of Tennessee v. James Mellon

Although the defendant, James A. Mellon, raises numerous issues on appeal, the dispositive issue is whether his guilty plea was unknowing and involuntary, and the subsequently imposed death sentence in violation of due process, when he was not adequately informed of the consequences should he breach the plea agreement. Prior to trial, the defendant pleaded guilty to felony murder and especially aggravated robbery as part of a plea agreement with the prosecution. The agreement provided that, in exchange for his pleas of guilty, the State would recommend a sentence of life in prison with the possibility of parole on the felony murder conviction and a concurrent sentence of fifteen to twenty-five years for the especially aggravated robbery conviction, with the trial court to decide the actual length of the sentence. Pursuant to the agreement, sentencing would be reserved until after testimony by the defendant in any related proceeding or at the conclusion of such proceedings. The defendant reneged on the agreement and instead moved to withdraw his guilty pleas. The trial court denied the defendant's motion and empaneled a jury. A sentencing hearing was conducted, resulting in a sentence of death. The Court of Criminal Appeals affirmed the conviction and death sentence for the felony murder. On automatic appeal to this Court, we conclude that the defendant was not adequately informed of the consequences if he should breach the plea agreement. We are constrained to hold that the defendant's pleas were not knowingly and voluntarily entered, and thus the subsequent sentence denied him due process of law. Therefore, we reverse the decision of the Court of Criminal Appeals and remand to the trial court for further proceedings consistent with this opinion.