State of Arizona v. Bennett Laquan Williams

Summary

The court held that expungement of the prior marijuana conviction eliminated the factual basis for Williams’s repeat-offender guilty plea and entitled him to post-conviction relief. It nevertheless held that the plea agreement was not automatically void; it became voidable if resentencing produced a sentence different from the agreed twelve-year term. The State may not substitute another prior felony under the existing agreement, although either party may withdraw under specified resentencing conditions.