State v. Angel M.

Summary

The court affirmed the judgment, holding that the sentencing court did not increase the defendant’s sentence for invoking his right against self-incrimination or refusing to apologize. The sentencing court expressly assured the defendant that maintaining his innocence would not be punished, and the sentence was attributable to the seriousness of the offenses and their effects on the victims rather than to the defendant’s silence. The court declined to decide whether the federal Constitution categorically bars considering a defendant’s denial of guilt or refusal to accept responsibility for any punitive sentencing purpose. Justice Ecker, concurring, agreed with the result but questioned whether conditioning leniency on apologizing for uncharged misconduct would violate the unconstitutional-conditions doctrine.