The People of the State of Colorado v. Christopher Anthon Mazzarelli

Summary

The court held that Colorado's plea-agreement statute and rules permit a defendant, but not the prosecution, to withdraw after the trial court accepts a guilty plea and rejects an agreed sentence concession. Sentence concessions are recommendations subject to the trial court's independent sentencing judgment, and permitting the court to reject the concession does not violate separation of powers. The court affirmed the court of appeals' judgment on different grounds and vacated that court's opinion in its entirety. Justice Boatright, joined by Justice Márquez, dissented, arguing that the rule is ambiguous and that the prosecution should be allowed to withdraw when the court materially changes the agreement.