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“[A] plea is involuntary when it is induced by coercive or deceptive action.”

“[A] plea is involuntary when it is induced by coercive or deceptive action.”

a petition for postconviction relief for an abuse of discretion, the overall question of whether [a defendant’s] guilty plea was valid presents a question of law that [appellate courts] review de novo.” (citations omitted).

see Tollett v. Henderson, 411 U.S. 258, 267 (1973) (“[A] guilty plea represents a break in the chain of events which has preceded it in the criminal process.

Moreover, an intelligent guilty plea must “represent a knowing and intelligent choice among the alternative courses of action available.” (quotation omitted).

then [the] plea was intelligently entered.”

A valid guilty plea waives “all non- jurisdictional defects arising prior to the entry of the plea.” d 873, 878 (Minn. 2017) (); see also Tollett v. Henderson, 411 U.S. 258, 267 (1973) (explaining that a criminal defendant who has pleaded guilty to a crime “may not thereafter raise independent claims relating to the deprivation of constitutional rights that occurred

“To be intelligent, a guilty plea must represent a knowing and intelligent choice among the alternative courses of action available.” (quotation omitted).

“[A] valid guilty plea waives all non-jurisdictional defects arising prior to the entry of the plea.” (quotation omitted).

“[A] plea is involuntary when it is induced by coercive or deceptive action.”

the promise of an illegal sentence.”

(applying de novo review to the validity of a guilty plea); Pearson, d at 600 (applying de novo review to a postconviction court’s analysis of claims of ineffective assistance of counsel).

The state “cannot induce a guilty plea based on a promise by the prosecutor that goes unfulfilled or was unfulfillable from the start, such as a plea agreement involving the promise of an illegal sentence.” (“A guilty plea cannot be induced by unfulfilled or unfulfillable promises .

The state “cannot induce a guilty 5 plea based on a promise that goes unfulfilled or was unfulfillable from the start.”

But “ a valid guilty plea waives all non - jurisdictional defects arising prior to the entry of the plea.” d 873, 878 (Minn. 2017) (quotation omitted) .

(rejecting an argument that would allow a defendant to challenge “any allegedly erroneous procedural or evidentiary ruling” because it undermined “the rule that only jurisdictional challenges may be entertained after a” guilty plea); (“[W]hen [ap

While a defendant has no absolute right to withdraw a guilty plea after entering it, a district court may allow withdrawal before sentencing when it is “fair and just” to do so.

eement “called for him to plead guilty to fourth- degree criminal sexual conduct —mentally [incapacitated],” and so “changing” the plea and conviction to an offense based on physical helplessness made the plea “a moving target and rendered it unintelligent.” An intelligent guilty plea is “a knowing and intelligent choice [among] the alternative courses of action available.”

mental coercion overbearing the will of the defendant.” d 873, 877 (Minn. 2017) (quotations omitted).

“To be intelligent, a guilty plea must represent a knowing and intelligent choice among the alternative courses of action available.” (quotation omitted).

10 as a waiver of all non- jurisdictional defects arising prior to the entry of the plea.” (declining to consider issue based on the “longstanding rule” that “a criminal defendant’s valid guilty plea waives all non-jurisdictional defects arising prior to the entry of the plea”); (applying the rule that “only jurisdictional challenges may be entertained after a criminal defendant has pleaded guilty”).

The intelligence of a plea depends on “what the defendant knew at the time he entered the plea.”

Appellant argues he is “entitled to withdraw his [guilty] plea because it was the product of the [district] court improperly forcing [ him] to be represented by [ counsel].” But a “valid guilty plea waives all non- jurisdictional defects arising prior to the entry of the plea.”6 d 873, 878 (Minn. 2017) (quotation omitted); see also Tollett v. Henderson, 411 U.S. 258, 267 (1973) (“[A] guilty plea represents a break in the chain of events which has preceded it in the criminal process.

(stating that guilty plea is involuntary when “based on a promise by the prosecutor that goes unfulfilled”); (stating that defendant should be allowed to withdraw guilty plea if an unqualified promise as to sentence is not fulfilled).