State of Minnesota, Respondent,

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-0402

State of Minnesota,
Respondent,

vs.

Austin Nathaniel Ouellette,
Appellant.

Filed February 2, 2026
Affirmed
Ross, Judge

Stearns County District Court
File No. 73-CR-24-4031

Keith Ellison, Attorney General, St. Paul, Minnesota; and

Janelle P. Kendall, Stearns County Attorney, Michael J. Lieberg, Chief Deputy County
Attorney, St. Cloud, Minnesota (for respondent)

Cathryn Middlebrook, Chief Appellate Public Defender, Jennifer Lauermann, Assistant
Public Defender, St. Paul, Minnesota (for appellant)

Considered and decided by Johnson, Presiding Judge; Ross, Judge; and Ede, Judge.
NONPRECEDENTIAL OPINION
ROSS, Judge
The state charged Austin Ouellette with two counts of third-degree criminal sexual
conduct based on his alleged sexual penetration of a minor, and he pleaded guilty to one
count in a negotiated plea deal with the state. Ouellette unsuccessfully moved for a rule 20
competency examination and later presented a sentencing memorandum that did not renew
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his request for a competency examination but argued for a downward dispositional
sentencing departure based on his alleged untreated mental-health issues. The district court
denied the departure motion and sentenced Ouellette to serve 41 months in prison.
Ouellette argues on appeal that we should reverse his conviction because he entered his
guilty plea involuntarily and unintelligently. Because the record demonstrates that
Ouellette was neither improperly pressured n or induced into entering his guilty plea and
that he understood its consequences, his argument fails and we affirm.
FACTS
The state charged Austin Ouellette in May 2024 with two counts of third-degree
criminal sexual conduct, alleging that he sexually penetrated a 14-year-old victim at his
home in St. Cloud. Ouellette and the state negotiated a plea deal in which, among other
terms, Ouellette would plead guilty to one count and the state would dismiss the other.
Ouellette appeared for his plea hearing in August 2024 and testified, waiving his
constitutional and related rights and admitting to the factual allegations of the offense. He
said that he had reviewed his guilty- plea petition line by line with his attorney, that he
intended to plead guilty, that his decision was not affected by his unspecified mental-health
condition, and that he had no mental disability or medical condition that affected his
decision. The district court accepted his guilty plea, scheduled sentencing for December,
and ordered a psychosexual evaluation as part of a presentence investigation (PSI).
About three weeks before the scheduled December sentencing hearing, Ouellette
moved the district court for a rule 20 competency evaluation. At a hearing on the motion,
the district court questioned Ouellette’s reason for the requested evaluation, and Ouellette
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said that jail staff and his physician treated him for mental disorders, including bipolar
disorder, schizophrenia, and autism, and that these impaired his perception of reality and
limited his understanding of the court proceedings. He asserted too that jail staff deprived
him of antipsychotic medication. He said also, contrary to his plea-petition statements, that
he had previously been hospitalized for psychiatric treatment. The district court stated that
Ouellette’s behavior and demeanor failed to raise any competency concerns, and it declined
to find his statements credible. The district court said that it would review the PSI report
and psychosexual evaluation to see if they revealed any competency issues.
Ouellette’s psychosexual evaluator opined that he did not qualify for a competency
evaluation. The evaluator reported that Ouellette suffered from some perceptual
distortions, which she believed may have resulted from his marijuana use. She said that
Ouellette did not meet the criteria for bipolar disorder but did manifest symptoms
consistent with autism. She noted that Ouellette was treated in custody with medication for
“serious mental illness,” but she offered no opinion as to how it affected his competency.
The PSI report integrated the evaluator’s findings into its recommendation for a 48-month
prison commitment.
Ouellette appeared for sentencing with counsel and did not renew his request for a
competency evaluation. He instead moved for a downward dispositional sentencing
departure, arguing that a probationary sentence would allow him to undergo a
comprehensive mental-health evaluation and to pursue treatment. The district court
sentenced Ouellette to serve 41 months in prison followed by ten years of conditional
release and predatory-offender registration.
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Ouellette appeals.
DECISION
Ouellette contends on appeal that we should reverse his conviction to correct a
manifest injustice, arguing that his guilty plea was invalid because it was neither voluntary
nor intelligent. See Minn. R. Crim. P. 15.05, subd. 1 ; Dikken v. State, 896 N.W.2d 873,
876–77 (Minn. 2017). Ouellette bears the burden of showing that his plea was invalid. See
State v. Raleigh, 778 N.W.2d 90, 94 (Minn. 2010). He fails to meet that burden.
I
We are unconvinced that Ouellette’s guilty plea was not voluntary based on his
contention that the plea was coerced because he did not comprehend the nature of his plea
hearing or understand the questions he answered. We review the issue de novo. Id. A
defendant’s plea is involuntary when his plea decision results from improper pressure or
was induced by government action that threatened him with harm, deceived him with
unfulfilled promises, or mentally overbore his will. Dikken , 896 N.W.2d at 876–77.
Ouellette identifies no governmental action as the source of any pressure, implying that his
own alleged mental illness pressured or induced his plea. He offers no legal support for his
implicit theory that pressure resulting from his mental -health issues can render his plea
involuntary.
And Ouellette unpersuasively incorporates competency as an element of a
voluntariness analysis. Competency involves a defendant’s ability to consult with his
attorney and understand the proceedings against him, Bonga v. State, 797 N.W.2d 712, 718
(Minn. 2011), while involuntariness involves external pressure or inducement. See Dikken,
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896 N.W.2d at 877. Ouellette cites State v. Trott, 338 N.W.2d 248, 248 (Minn. 1983), for
the proposition that “voluntariness of [his] guilty plea generally comprises two inquiries
[including] whether Ouellette had the mental capacity or competence to understand his
rights and enter the plea rationally.” But the Trott decision does not support the argument,
mentioning neither “capacity” nor “competence” as elements of a voluntariness inquiry. In
any event, we are satisfied from the record that Ouellette’s implicit challenge to the district
court’s competency-evaluation decision fails . The district court determined that his
demeanor and behavior raised no competency concerns, and Ouellette did not challenge
the district court’s implied conclusion that the psychosexual evaluation also raised no such
concerns. Ouellette’s voluntariness argument does not lead us to reverse.
II
We are also unconvinced by Ouellette’s argument that his guilty plea was not
intelligent. A plea is intelligent when the defendant understands the charges, the rights he
is waiving, and the plea’s consequences. Dikken, 896 N.W.2d at 877 . Ouellette contends
that his inconclusive diagnoses of mental disorders and his statements about lacking
understanding during the motion hearing demonstrate that he did not understand the
consequences of his plea. But the district court was unpersuaded that his claimed lack of
understanding was credible. And a defendant cannot successfully attack his guilty plea with
a factual argument that contradicts his plea-hearing testimony. See Coolen v. State, 179
N.W.2d 81, 86 (Minn. 1970). Ouellette’s testimony that his plea answers were true and
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correct, that his medication did not affect his decision, and that he fully understood his
waiver of trial rights, defeats his contention that he pleaded guilty unintelligently.
Affirmed.