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State v. Cyr

Citations: 449 A.2d 926; 141 Vt. 355; 1982 Vt. LEXIS 529Docket: 121-81

Court: Supreme Court of Vermont; June 10, 1982; Vermont; State Supreme Court

Narrative Opinion Summary

The case involves a defendant charged with unlawful trespass, two counts of simple assault, and disorderly conduct following an incident in a hotel. The defendant entered nolo contendere pleas to the assault charges as part of a plea agreement, resulting in the dismissal of other charges. He was sentenced to concurrent terms of 32 days to one year, with part of the time to be served on weekends. The defendant later sought to withdraw his pleas and reduce his sentence, both of which were denied by the trial court. The defendant argued that the presentence report's inclusion of uncharged prior criminal conduct constituted manifest injustice, but the court found this argument unpersuasive, noting that the sentencing judge did not consider these assertions in determining the sentence. Additionally, the defendant's claim that the court abused its discretion by not considering sentences in related cases was rejected, as the court found no exceptional circumstances and affirmed the sentence as justified by the presentence report and the circumstances of the offenses. The trial court's decisions were affirmed, with no evidence of prejudice or abuse of discretion in the sentencing process.

Legal Issues Addressed

Consideration of Uncharged Conduct in Sentencing

Application: The court distinguished this case from State v. Williams, holding that the sentencing judge did not improperly consider unproven assertions of prior conduct in determining the sentence.

Reasoning: The court noted that the sentencing judge did not consider these unproven assertions in imposing the sentence.

Judicial Discretion in Sentencing

Application: The trial court's decision not to consider sentences in related cases was upheld, as there were no exceptional circumstances warranting review of the sentence lengths within statutory limits.

Reasoning: The court maintained that it would not review sentence lengths within statutory limits without exceptional circumstances, which were not present.

Withdrawal of Nolo Contendere Plea

Application: The defendant's argument to withdraw his nolo contendere pleas based on the inclusion of uncharged prior criminal conduct in the presentence report was rejected as it did not constitute manifest injustice.

Reasoning: Cyr argued that the inclusion of uncharged prior criminal conduct in the presentence report constituted manifest injustice, necessitating the withdrawal of his pleas.