Cited by

-19 (Minn. 1994); see also Raleigh, d at 96 (instructing courts to examine what the parties understood to be the terms of the plea agreement).

To be constitutionally valid, a guilty plea must be “accurate, voluntary and intelligent.”

In a Norgaard plea, a defendant pleads guilty “even though he or she claims a loss of memory, through amnesia or intoxication, regarding the circumstances of the offense.” -17 (Minn. 1994); see State ex rel.

“A proper factual basis must be established for a guilty plea to be accurate.”

They impair my judgment and my mental health.” The district court then said that it “[did not] likely to be convicted of the crime charged.” -17 (Minn. 1994) (citing State ex rel.

“When an accused is represented by counsel, the 6 voluntariness of the plea depends on whether counsel’s advice was within the range of competence demanded of attorneys in criminal cases.” (quotations omitted).

The state “may not produce a plea by actual or threatened physical harm or by mental coercion overbearing the will of the defendant.” 15 Brady v. United States, 397 U.S. 742, 750 (1970)

And the state may not secure a guilty plea “through actual or threate ned physical harm or by mental coercion [that] ‘overbear[s] the will of the 12 defendant.’” (), rev. denied (Minn. Aug.

1; -16 (Minn. 1994) (applying Minn. R. Crim.

d 712, 718 (Minn. 1994).

[the defendant] would not have pleaded guilty.” (quoting Strickland v. Washington, 466 U.S. 668, 688, 694 (1984)).

But in determining plea accuracy, “an adequate factual basis is usually established by questioning the defendant.”

Cf. State v. Ecker , d 712, 718-19 (Minn. 1994) (“[A] defendant’s motivation to avoid a more serious penalty or set of charges will not invalidate a guilty plea.”); Raleigh, d at 96 (“Raleigh offers no further explanation of how stress, irrational thinking, improper pressure, or coercion influenced his plea decision .

While the Minnesota Supreme Court has discouraged the use of leading questions to establish the factual basis for a guilty plea, see, “the use of 8 leading questions will not on its own invalidate a guilty plea,” d 391, 398 (Minn. 2024).

For a plea to be accurate, it “must be established on a proper factual basis.” Raleigh, d at 94 ().

-17 (Minn. 1994); State ex rel.

The state may not secure a guilty plea “through actual or threatened physical harm or by mental coercion that ‘overbear[s] the will of the defendant.’” (), rev. denied (Minn. Aug.

1 Under an Alford plea, “a defendant may plead guilty to an offense, even though the defendant maintains his or her innocence, if the defendant reasonably believes, and the record establishes, the state has sufficient evidence to obtain a conviction.”

see, e.g. , –17 (Minn. 1994) (distinguishing the factual basis of straight pleas from Alford and Norgaard pleas); 588–89 (Minn. 2012) (stating that grand-jury transcript may supplement plea colloquy where it was admitted at plea hearing and acknowledged by defendant); State v. Trott

aff’d on other grounds, 1 The state argued that appellant did not brief a claim of ineffective assistance of counsel to the postconviction court and thereby forfeited the claim on appeal.

-17 (Minn. 1994) (citing State ex rel.

The purpose of the accuracy requirement is to “protect[] the defendant from pleading guilty to a charge more serious than he or she could be convicted of were the defendant to go to trial.”

A guilty plea is 6 not voluntary if it results from “mental coercion overbearing the will of the defendant.” (quotation omitted).

d 712, 716-17 (Minn. 1994); State ex rel.

A guilty plea is valid if it is “accurate, voluntary and intelligent.” ().

“A proper factual basis must be established for a guilty plea to be accurate.”

“A proper factual basis must be established for a guilty plea to be accurate.”

In denying 1 A Norgaard plea allows a defendant to “plead guilty even though he or she claims a loss of memory, through amnesia or intoxication, regarding the circumstances of the offense.” see State ex rel.

Beaulieu argues his plea was involuntary because “he felt forced into pleading guilty because he did not feel that [his] lawyer was prepared to proceed to trial.” Whether a plea is involuntary due to ineffective assistance of counsel “depends on whether counsel’s advice was within the range of competence demanded of attorneys in criminal cases.” State v. Ecker , (quotation omitted).

The state “may not produce a plea by actual or threatened physical harm or by mental coercion overbearing the will of the defendant.” Brady v. United States, 397 U.S. 742, 750 (1970)

In Taylor, the supreme court held that predatory 3 To be valid, a guilty plea must be “accurate, voluntary and intelligent.”

For a discussion of Norgaard pleas, (“A defendant may also plead guilty even though he or she claims a loss of memory, through amnesia or intoxication, regarding the circumstances of the offense.