People of Michigan v. Dwight T Samuels

Summary

The Court held that when a package-deal plea raises a substantiated factual question about voluntariness and the defendant's plea-hearing testimony does not directly contradict the claim, the trial court must conduct an evidentiary hearing. At that hearing, the court must assess the totality of the circumstances using nonexclusive factors addressing the inducement, factual basis, coercion, significance of leniency to the third party, and other relevant circumstances. Because Samuels changed from requesting a trial to pleading guilty only after his twin brother accepted the offer, he was entitled to such a hearing, and the judgment below was reversed.