State v. Angel M.

Summary

The court affirmed the judgment, holding that the sentencing court did not increase the defendant’s sentence for maintaining his innocence or declining to apologize. The sentencing record expressly assured the defendant that he would not be punished for exercising his constitutional right, while permissibly denying him additional leniency that might have followed an acceptance of responsibility. The court did not decide whether the federal Constitution categorically bars consideration of a defendant’s refusal to admit guilt at sentencing. Ecker, J., joined by McDonald, J., concurred, agreeing with the result but questioning whether conditioning leniency on an apology for uncharged misconduct would satisfy the unconstitutional-conditions doctrine.