Cited by
Opinions in Minnesota that cite Dikken v. State, 896 N.W.2d 873.
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State of Minnesota v. Rolland Laverne Basswood
Minn. Ct. App. 2026
A defendant “does not have an absolute right to withdraw a guilty plea once 6 it has been entered.” (quotation omitted).
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Lavell Jacvon Piggie v. State of Minnesota
Minn. Ct. App. 2026
“Although [appellate courts] review the denial of an evidentiary hearing and a petition for postconviction relief for an abuse of discretion, the overall question of whether [the petitioner’s] guilty plea was valid presents a question of law that [appellate courts] review de novo.” (citations omitted).
- State of Minnesota v. Robbie Garnet Johnson Minn. Ct. App. 2026
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Marshall Adrian Pack v. State of Minnesota
Minn. Ct. App. 2026
“[A] plea is involuntary when it is induced by coercive or deceptive action.”
- Ricardo Daniel Peralta Gutierrez v. State of Minnesota Minn. Ct. App. 2026
- State of Minnesota v. Austin Nathaniel Ouellette Minn. Ct. App. 2026
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Ellis Scott Tooles v. State of Minnesota
Minn. Ct. App. 2026
“[A] plea is involuntary when it is induced by coercive or deceptive action.”
- Steven Robert Anderson v. State of Minnesota Minn. Ct. App. 2026
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Steven Robert Anderson v. State of Minnesota
Minn. Ct. App. 2026
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).
- State of Minnesota v. James Allan Denker Minn. Ct. App. 2026
- State of Minnesota v. James Allan Denker Minn. Ct. App. 2026
- State of Minnesota v. Christopher Lawrence Hunt Minn. Ct. App. 2025
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State of Minnesota v. Christopher Lawrence Hunt
Minn. Ct. App. 2025
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.
- Michael Edmund Richmond, petitioner, Appellant, vs. State of Minnesota, Respondent Minn. Ct. App. 2025
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Michael Edmund Richmond, petitioner, Appellant, vs. State of Minnesota, Respondent
Minn. Ct. App. 2025
Moreover, an intelligent guilty plea must “represent a knowing and intelligent choice among the alternative courses of action available.” (quotation omitted).
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State of Minnesota v. Larry Tabell Davis
Minn. Ct. App. 2025
then [the] plea was intelligently entered.”
- Kayd Mohamed Falug v. State of Minnesota Minn. Ct. App. 2025
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Reginald Scott Hubbard v. State of Minnesota
Minn. Ct. App. 2025
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
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State of Minnesota v. Thomas Jay Shern
Minn. Ct. App. 2025
“To be intelligent, a guilty plea must represent a knowing and intelligent choice among the alternative courses of action available.” (quotation omitted).
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State of Minnesota v. Nick Adam Schouviller
Minn. Ct. App. 2025
“[A] valid guilty plea waives all non-jurisdictional defects arising prior to the entry of the plea.” (quotation omitted).
- State of Minnesota v. Delmarcus Deante Joseph Minn. Ct. App. 2025
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Andrew Charles Patton v. State of Minnesota
Minn. Ct. App. 2025
“[A] plea is involuntary when it is induced by coercive or deceptive action.”
- State of Minnesota v. Matthew Michael Lewis Minn. Ct. App. 2025
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State of Minnesota v. Matthew Michael Lewis
Minn. Ct. App. 2025
the promise of an illegal sentence.”
- State of Minnesota, Respondent, vs. Henry Lee Brown, Appellant Minn. 2025
- State of Minnesota, Respondent, vs. Henry Lee Brown, Appellant Minn. 2025
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Stacy Lee Row v. State of Minnesota
Minn. Ct. App. 2025
(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).
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State of Minnesota v. Shawn Elson Randall
Minn. Ct. App. 2025
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 .
- Germaine Yurii Butler v. State of Minnesota Minn. Ct. App. 2025
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Daniel John Wyatt v. State of Minnesota
Minn. Ct. App. 2024
The state “cannot induce a guilty 5 plea based on a promise that goes unfulfilled or was unfulfillable from the start.”
- State of Minnesota v. Laron Lovell Brown Minn. Ct. App. 2024
- State of Minnesota v. Laron Lovell Brown Minn. Ct. App. 2024
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State of Minnesota v. Kenny Lenard Peaches
Minn. Ct. App. 2024
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) .
- State of Minnesota v. Kenny Lenard Peaches Minn. Ct. App. 2024
- State of Minnesota v. Marvel Galvaston Williams Minn. Ct. App. 2024
- State of Minnesota v. Marvel Galvaston Williams Minn. Ct. App. 2024
- Omar Kwabena Walford v. State of Minnesota Minn. Ct. App. 2024
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Omar Kwabena Walford v. State of Minnesota
Minn. Ct. App. 2024
(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
- State of Minnesota v. Henry Lee Brown Minn. Ct. App. 2024
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State of Minnesota v. Henry Lee Brown
Minn. Ct. App. 2024
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.
- State of Minnesota v. Daniel John Wyatt Minn. Ct. App. 2023
- State of Minnesota v. Daniel John Wyatt Minn. Ct. App. 2023
- State of Minnesota v. Dorothy Shavon Green Minn. Ct. App. 2023
- State of Minnesota v. Micah Montre Marrison Minn. Ct. App. 2023
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Todd Deon Rolack v. State of Minnesota
Minn. Ct. App. 2023
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.”
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State of Minnesota v. Nathan Christopher Braun
Minn. Ct. App. 2023
mental coercion overbearing the will of the defendant.” d 873, 877 (Minn. 2017) (quotations omitted).
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State of Minnesota v. Joshua William Dwyer
Minn. Ct. App. 2023
“To be intelligent, a guilty plea must represent a knowing and intelligent choice among the alternative courses of action available.” (quotation omitted).
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State of Minnesota v. Matthew Douglas Paulson
Minn. Ct. App. 2023
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”).
- State of Minnesota v. Shevirio Kavirion Childs -Young Minn. Ct. App. 2023
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State of Minnesota v. Jerelle Anthony Ellis
Minn. Ct. App. 2023
The intelligence of a plea depends on “what the defendant knew at the time he entered the plea.”