State v. Tate
At age 17, Brian Tate pled guilty to murder. Although Brian had dropped out of high school, had a mental health diagnosis, and a history of drug abuse, the trial court accepted Mr. Tate’s pleas without considering whether his age, limited education, or mental impairments affected the voluntariness of the plea, and sentenced Mr. Tate to life in prison.
Ballard Sparhr LLP filed an amicus brief on behalf of Juvenile Law Center in support of Mr. Tate in the Maryland Court of Appeals—Maryland’s final appellate court. Our brief argued that a juvenile defendant's age, mental health status, and developmental characteristics must be considered in assessing if a youth's guilty plea was knowing and voluntary.
The Maryland Court of Appeals acknowledged that a defendant’s “youth, the complexity of the charges, and the extent of the plea colloquy are relevant considerations” in determining the voluntariness of a plea, but held that Mr. Tate’s guilty plea was voluntary under the totality of the circumstances.