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“[M]anifest injustice exists where a guilty plea is invalid.”

(explaining, in the context of an Alford plea, “[t]he allegations of the complaint in this case also do not satisfy .

Although the fair-and-just standard is “less demanding than the manifest injustice standard, it does not allow a defendant to withdraw a guilty plea for simply any reason.” State v. Theis , d 643, 646 (Minn. 2007) (quotation omitted).

(quoting North Carolina v. Alford, 400 U.S. 25, 38 (1970)).

Although it is a lower burden, the fair-and-just standard “does not allow a defendant to withdraw a guilty plea for simply any reason.” State v. Theis , d 643, 646 (Minn. 2007) (quotation omitted).

accurate Alford plea involves the following: (1) a strong factual basis, (2) an admission from the defendant that the evidence is sufficient to convict him at trial, and (3) the district court’s independent conclusion that “there is a strong probability that the defendant would be found guilty of the charge to which he pleaded guilty, notwithstanding his claims of innocence.”

“A defendant does not have an absolute right to withdraw a valid guilty plea.”

at 13 (quoting State v. Theis , ).

The accuracy requirement of a valid guilty plea protects a defendant “from pleading guilty to a more serious offense than he could be convicted of were he to insist on his right to trial.” ().

“A proper factual basis must be established for a guilty plea to be accurate.” (quotation omitted).

(quoting North Carolina v. Alford, 400 U.S. 25, 38 (1970)).

than the manifest-injustice standard, but it does not permit withdrawal of ‘a guilty plea for simply any reason.’” (d 643, 646 (Minn. 2007)).

“If a plea fails to meet any one of these requirements, it is invalid.”

The state 1A defendant enters an Alford guilty plea if he maintains his innocence but has “clearly expressed his desire to enter the plea based on his belief that the State’s evidence would be sufficient to convict him.” (citing North Carolina v. Alford, 400 U.S. 25, 38 (1970)).

State v. Theis , (citing North Carolina v. Alford, 400 U.S. 25, 38 (1970)).

at 13 (d 643, 649 (Minn. 2007)).

State v. Theis , Minn. R. Crim.

An Alford plea permits “a court to accept a defendant’s guilty plea, even though the defendant [maintains] his innocence, where the State [demonstrates] ‘a strong factual basis for the plea’ and the defendant clearly [expresses] his desire to enter the plea based on his belief that the State’s evidence would be sufficient to convict him.” (quoting North Carolina v. Alford, 400 U.S. 25 (1970)).

State v. Theis , -49 (Minn. 2007).

“[C]areful scrutiny of the factual basis for the plea is necessary within the context of an Alford plea because of the inherent conflict in pleading guilty while maintaining innocence.” State v. Theis , -49 (Minn. 2007).