Due to an error in legal procedure, a Grangeville man currently serving a 3-to-9-year prison sentence on a felony sex abuse charge will be returning to court for a review of his conviction.
Larry Lee James Stadtmiller, 42, was found guilty at trial in 2012 for sexual abuse of an 11-year-old minor female committed the year prior. He subsequently appealed his conviction on two points: one that the District Court abused its discretion by not acting consistently with legal standards in rejecting his Alford plea; and the second, that the court abused its discretion by imposing the 3-to-9-year sentence by failing to consider mitigating factors of Stadtmiller’s substance abuse and the support of his family.
In a nine-page May 13 opinion by the Idaho Court of Appeals, the prison sentence was affirmed based on a review of the record showing adequate consideration was given by sentencing District Judge Michael Griffin to mitigating factors presented by the defense. However, the appeals court did agree in an abuse of discretion regarding the Alford plea rejection, and it has been remanded back to the District Court for reconsideration.
Stadtmiller is set for a hearing in District Court on June 9.
An Alford plea is where a defendant states he or she did not commit the offense being charged with; however, fearing more severe penalties, he or she enters a plea of guilty.
In Stadtmiller’s case, the District Court rejected his first attempted Alford plea — pleading guilty in exchange for an amended felony charge of injury to a child — because he “did not admit any guilt, and because he had not been under the influence of drugs or alcohol to the point where he did not remember the incident,” according to the appeal court opinion.
The applicable standard in an Alford plea is an individual accused of a crime may voluntarily, knowingly, and understandingly consent to the imposition of a prison sentence even if he is unwilling or unable to admit his participation in the acts constituting the crime.
The appeals court agreed the District Court’s rejecting Stadtmiller’s Alford plea was an error in not acting consistently with the applicable legal standard. As a result, it has ordered the District Court to reconsider Stadtmiller’s original Alford plea, the action on which may affect his currently imposed prison sentence.