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However, “a court must allow a defendant to withdraw a guilty plea, even after sentencing, if ‘withdra wal is necessary to correct a manifest injustice.’” (quoting Minn. R. 3 Crim.

(holding a plea invalid when it was not accurate).

Instead, he argues that “it would have at least been fair and just to allow him to withdraw his plea.” 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.” (quotation omitted).

(stating that “the court must be able to determin e that the defendant, despite maintaining his innocence, agrees that evidence the [s]tate is likely to offer at trial is sufficient to convict” ).

However, “a court must allow a defendant to withdraw a guilty plea, even after sentencing, if ‘withdrawal is necessary to correct a manifest injustice.’” (quoting Minn. R. Crim.

State v. Theis , see also North Carolina v. Alford , 400 U.S. 25, 38, 91 S. Ct. 160, 168 (1970) (holding that in s ome circumstances, a court may cons titutionally accept a defendant’ s guilty plea even though the defendant maintained his innocence).

1; (examining manifest injustice as a threshold matter although the appellant only raised the fair-and-just standard on appeal).

State v. Theis , (citing North Carolina v. Alford, 400 U.S. 25, 38, 91 S. Ct. 160, 167–68 (1970)).

See State v. Theis , d 643, 646 (Minn. 2007).

State v. Theis , , 647 (Minn. 2007) (citing North Carolina v. Alford , 400 U.S. 25 , 38, 91 S.Ct.

d 643, 646 (Minn. 2007).

State v. Theis , d 643, 646 (Minn. 2007).

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

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.” (quotation omitted).

While 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.” d 643, 646 (Minn. 2007) (quotation omitted).

d 643, 646 (Minn. 2007).

Because of the inherent conflict between pleading guilty and maintaining innocence, caselaw requires a “strong factual basis for an Alford plea.”

Although the fair-and-just standard “is less 5 demanding” than the manifest-injustice sta ndard, “it does not allow a defendant to withdraw a guilty plea for simply any reason.” (quotation omitted).

An Alford plea is accurate if (1) it is established by a proper factual basis, which exists if the plea is based on “evidence discussed with t he defendant on the record at the plea hearing” and (2) the defendant “agrees that evidence the State is likely to offer at trial is sufficient to convict.”