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A defendant must demonstrate that “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” (quotation omitted).

A. 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.”

d 712, 718 (Minn. 1994) (holding that appellant failed to show prejudice to support 13 guilty-plea withdrawal based on alleged ineffective assistance in failing to investigate possible exculpatory witnesses and defenses when appellant did not “show [that] witnesses would have been found” or that “any defense .

“The accuracy requirement protects the defendant from pleading guilty to a charge more serious than he could have been convicted of at trial.” ().

When a defendant claims a loss of memory, through amnesia or intoxication, regarding the circumstances of the offense, they may plea d guilty via a Norgaard plea if the record establishes “that the evidence against the defendant is sufficient to persuade the defendant and his or her counsel that the defendant is guilty or likely to be convicted of the crime charged.”

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

A threat to prosecute a criminal defendant fully if they do not plead guilty is constitutional, and “a defendant’s motivation to avoid a more serious penalty or set of charges will not invalidate a guilty plea.” (citing Brady v. United States, 397 U.S. 742, 750-51 (1970)).

regarding the circumstances of the offense,” but the record “establish[es] that the evidence against the defendant is sufficient to persuade the defendant and his or her counsel that the defendant is guilty or likely to be convicted of the crime charged.” -17 (Minn. 1994) (citations omitted); see also State ex rel.

State v. Ecker , - 17 (Minn. 1994) (citing State ex rel.

at 647, 649; see State v. Ecker , d 712, 717 (Minn. 1994) (concluding that factual basis established intent element “based on [defendant’s] probable guilt and the likelihood a jury would convict him”).

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

For a guilty plea to be accurate, “[a] proper factual basis must be established.”

See, (holding that defendant did not need to express the requisite intent for the charged crime); (same).

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

2 At the plea hearing, Bastyr indicated that she 1 A defendant may enter a Norgaard plea when the defendant “claims a loss of memory” but the record “establish[es] that the evidence against the defendant is sufficient to persuade the defendant and his or her counsel that the defendant is guilty or likely to be convicted of the crime charged.” -17 (Minn. 1994); see also State ex rel.

., Raleigh, d at 94-96 (concluding that the guilty plea was accurate and explaining that “the factual basis for [the] plea [was] sufficient, despite its disfavored format”); d 5 852, 860 (Minn. 2016) (collecting cases and observing that “we have never held that the use of leading questions automatically invalidates a guilty plea”); -17 (Minn. 1994) (concluding that the guilty plea was accurate despite use of leading questions to establish the factual basis and the failure of the parties to expli

“[A] threat to prosecute fully a defendant if he or she does not plead guilty is constitutional.”

an adequate factual basis is usually established by questioning the defendant and asking the defendant to explain in his or her own words the circumstances surrounding the crime.” d 712, 716 (Minn. 1994) .

“[T]he government may not produce a plea through actual or threatened physical harm, or by mental coercion overbearing the will of the defendant.” (quotation omitted) .

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

The supreme court has recognized that “[a] defendant ’s motivation to avoid a more serious penalty or set of charges will not invalidate a guilty plea.” see also Saliterman v. State , - 44 (Minn. App. 1989) (rejecting ineffective-assistance-of-counsel claim where defendant was advised of and accepted a plea agreement to dismiss three of five charges), rev. denied (Minn. Oct.

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

Ortiz “denied any hist ory of sexual abuse” during the evaluation and Dr. Aiken 1 “A defendant may enter a Norgaard plea when he or she is unable to remember the specific facts of the offense because of intoxication or amnesia but is persuaded that he or she is likely to be convicted of the crime charged.” n.1 (Minn. 2016) (-17 (Minn. 1994); State ex rel.

regarding the circumstances of the offense,” but the record “establish [es] that the evidence against the defendant is sufficient to persuade the defendant and his or her counsel that the defendant is guilty or likely to be convicted of the crime charged.”

“In a typical plea, where the defend ant admits his or her guilt, an adequate factual basis is usually established by questioning the defendant and asking the defendant to explain in his or her own words the circumstances surrounding the crime.”

Specifically, we must determine whether McReynolds’ guilty plea was “accurate.” State v. Ecker

regarding the circumstances of the offense,” but the record “establish[es] that the evidence against the defendant is sufficient to persuade the defendant and his or her counsel that the defendant is guilty or like ly to be convicted of the crime charged.” -17 (Minn. 1994) (citations omitted); see also State ex rel.

An Alford plea is appropriate when a defendant maintains his innocence, but otherwise “reasonably believes, and the record establishes, the state has sufficient evidence to obtain a conviction.” (citing North Carolina v. Alford, 400 U.S. 25, 37 (1970) ).

“The voluntariness requirement [e]nsures the defendant is not pleading guilty because of improper pressures.”

18 “[T]he voluntariness of the plea depends on whether counsel’s advice was within the range of competence demanded of attorneys in criminal cases.” State v. Ecker

“In order for a guilty plea to be valid, it must be made voluntarily.”

See State v. Ecker , see also Dikken, d at 877.

v. Ecker, (addressing claim of ineffective assistance of plea counsel as part of the voluntariness of the pl ea).

Similarly, for a guilty plea to be valid, it must be “accurate, volunt ary and intelligent.” State v. Ecker

d 867 (Minn. 1961); (explaining that when the defendant pleads guilty with a Norgaard plea, “the record must establish that the evidence .

A plea is considered accurate if it is supported by a “proper factual basis.”

(stating that an improper pressure involves “actual or threatened physical harm, or by mental coercion ov erbearing the will of the defe ndant” (quotation omitted)).

Nonetheless, the use of leading questions “does not by itself invalidate a guilty plea.” 914 (Minn. App. 2011) (); see also Raleigh, d at 95.