Cited by
Opinions in Minnesota that cite State v. Mikulak, 903 N.W.2d 600.
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State of Minnesota v. Rolland Laverne Basswood
Minn. Ct. App. 2026
To be clear, Basswood “must know that he is violating the statute when the violation occurs.”
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John Kevin Melina v. State of Minnesota
Minn. Ct. App. 2026
The accuracy requirement “protects the defendant from pleading guilty to a charge more serious than he could have been convicted of at trial.”
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State of Minnesota v. Leonard Steven Sanchez
Minn. Ct. App. 2026
“Once a guilty plea has been entered, there is no absolute right to withdraw it.”
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State of Minnesota v. Terry Izeal Heggs
Minn. Ct. App. 2026
“The plain text of the statute suggests that the defendant must know that he is violating the statute when the violation occurs.” d 600, 603 (Minn. 2017).
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State of Minnesota v. Rashad Lavonte Lenear
Minn. Ct. App. 2026
“Once a guilty plea has been entered, there is no absolute right to withdraw it.”
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Shawn Patrick Agar v. State of Minnesota
Minn. Ct. App. 2026
“Once a guilty plea has been entered, there is no absolute right to withdraw it.”
- Michael Edmund Richmond, petitioner, Appellant, vs. State of Minnesota, Respondent Minn. Ct. App. 2025
- Michael Edmund Richmond, petitioner, Appellant, vs. State of Minnesota, Respondent Minn. Ct. App. 2025
- State of Minnesota v. Gary Wayne Smith Minn. Ct. App. 2025
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State of Minnesota v. Gary Wayne Smith
Minn. Ct. App. 2025
“Once a guilty plea has been entered, there is no absolute right to withdraw it.”
- State of Minnesota v. Sadiq Aden Isack Minn. Ct. App. 2025
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State of Minnesota v. Shawn Henry Wellner
Minn. Ct. App. 2025
“Knowingly” is an adverb that modifies “violates.”
- Andrew Charles Patton v. State of Minnesota Minn. Ct. App. 2025
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State of Minnesota v. Mykell Steffon Burton
Minn. Ct. App. 2025
(noting that statements conflicting with a valid plea may be “withdrawn or corrected”).
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State of Minnesota v. Claude Michael McGriff
Minn. Ct. App. 2025
This is unlike State 6 v. Mikulak, in which the defendant’s “statements negated the mens rea element of the charged offense” and the Minnesota Supreme Court consequently held that “the factual basis fail[ed] to satisfy the accuracy requirement.”
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State of Minnesota v. Kemaludin Nuredin Mohammed
Minn. Ct. App. 2024
9 Mohammed insists that he made a statement negating his guilt of at least one essential element of first -degree aggravated robbery and that the accuracy of his plea could be rehabilitated only if he withdrew or corrected his purportedly problematic statement.
- State of Minnesota v. Mickela Joy Vredenburg Minn. Ct. App. 2024
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State of Minnesota v. Shawn Christopher Brown
Minn. Ct. App. 2024
“[A] factual basis is inadequate when the defendant makes stateme nts that negate an essential element of the charged crime because such statements are inconsistent with a plea of guilty.” (quotation omitted).
- Joel Armen Underwood, III v. State of Minnesota 8 N.W.3d 655 Minn. Ct. App. 2024
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Joel Armen Underwood, III v. State of Minnesota
8 N.W.3d 655
Minn. Ct. App. 2024
Although ignorance of the law is generally not a defense, knowledge of the law is an element of an offense “when the statute’s text requires it.” n.5 (Minn. 2017).
- State of Minnesota v. Sylvester Jones 7 N.W.3d 391 Minn. 2024
- State of Minnesota v. Sylvester Jones 7 N.W.3d 391 Minn. 2024
- Fidele Ndaruhutse v. State of Minnesota Minn. Ct. App. 2024
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Fidele Ndaruhutse v. State of Minnesota
Minn. Ct. App. 2024
And “[t]he defendant bears the burden of establishing the facts that support his claim that the guilty plea is invalid.”
- State of Minnesota v. Brent William Kruse Minn. Ct. App. 2024
- State of Minnesota v. Brent William Kruse Minn. Ct. App. 2024
- State of Minnesota v. William Joseph Garbow Minn. Ct. App. 2024
- State of Minnesota v. Abdullahi Abshir Abdullahi Minn. Ct. App. 2023
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State of Minnesota v. Sovajie Marion Julian Temple
Minn. Ct. App. 2023
“The accuracy requirement protects the defendant from pleading guilty to a charge more serious than he could have been convicted of at trial.” ().
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Todd Deon Rolack v. State of Minnesota
Minn. Ct. App. 2023
“For a guilty plea to be accurate, a proper factual basis must be established.”
- State of Minnesota v. Mark Allen Lacek Minn. Ct. App. 2023
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State of Minnesota v. Andre Shyron Kidd
Minn. Ct. App. 2023
“The accuracy requirement protects the defendant from pleading guilty to a charge more serious than he could have been convicted of at trial.” d 600, 603 (Minn. 2017) .
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State of Minnesota v. Tobias Osric Smith
Minn. Ct. App. 2023
The accuracy standard “protects the defendant from pleading guilty to a charge more serious than he could have been convicted of at trial.”
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Jason Elliot Peterson v. State of Minnesota
Minn. Ct. App. 2023
“[K]nowledge of the law at the time of the violation is an element of the offense of knowingly violating a provision of the predatory-offender- registration statute.”
- State of Minnesota v. Anthony Barrett Graham Minn. Ct. App. 2023
- State of Minnesota v. Corey Duane Warner Minn. Ct. App. 2023
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State of Minnesota v. Sylvester Jones
Minn. Ct. App. 2023
(reversing a conviction after a guilty plea where during the plea colloquy, the defendant stated he did not knowingly violate the predatory offender registration statute and this statement was not 2 Portions of Jones’s brief appear to argue that his statement at the sentencing hearing indicate
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State of Minnesota v. Matthew Allyn Defries
Minn. Ct. App. 2023
The accuracy standard “protects the defendant from pleading guilty to a charge more serious than he could have been convicted of at trial.”
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Deshon Israel Bonnell,
Minn. 2022
State v. Iverson , –50 (Minn. 2003); (holding that a guilty plea was inadequate when the defendant’s plea indicated that he did not “know” about the predatory registration requirement, thus negating the “knowingly” element of the crime).
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Pariss Demond Wright v. State of Minnesota
Minn. Ct. App. 2022
“The defendant bears the burden of establishing the facts that support his claim that the guilty plea is invalid.”
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Stephen Dontrail Thornton v. State of Minnesota
Minn. Ct. App. 2022
“The defendant bears the burden of establishing the facts that support his claim that the guilty plea is invalid.”
- Anthony Emerson Howson v. State of Minnesota Minn. Ct. App. 2022
- Dinesh Mongar v. State of Minnesota Minn. Ct. App. 2022
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State of Minnesota,
Minn. 2022
Lussier v. State , State v. Trott , –52 (Minn. 1983).
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State of Minnesota v. Jes Keven Johnson
Minn. Ct. App. 2022
“The defendant bears the burden of establishing the facts that support [their] claim that the guilty plea is invalid.”
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State of Minnesota v. Ryan Timothy Kellen
Minn. Ct. App. 2022
“The defendant bears the burden of establishing the facts that support his claim that the guilty plea is invalid.”
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State of Minnesota v. Juan Bustamante
Minn. Ct. App. 2022
“The defendant bears the burden of establishing the facts that support his claim that the guilty plea is invalid.”
- State of Minnesota, Minn. 2022
- State of Minnesota v. Irfan Beganovic Minn. Ct. App. 2022
- Christopher Lee Haugen v. State of Minnesota Minn. Ct. App. 2022