Cited by

5 (Minn. 1994) (observing that a record showing a voluntary guilty plea may preclude a claim that the plea was involuntary).

See Hill v. Lockhart, 474 U.S. 52, 56 (1985) (explaining that a defendant’s guilty plea may be constitutionally invalid if the defendant received ineffective assistance of counsel, rendering his guilty plea involuntary ); (“When an accused is represented by counsel, the voluntariness of the plea depends on whether counsel’s advice was within the range of competence demanded of attorneys in criminal cases.” (citations omitted) (internal quotation marks omitted)) .

(), review denied (Minn. Apr.

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

A valid 6 guilty plea is “accurate, vol untary and intelligent.”

(quoting Brady v. United States , 397 U.S. 742, 750, 90 S. Ct. 1463, 1470 (1970)).

6 12 (Minn. App. 2009) (), review denied (Minn. Apr.

“A plea is involuntary when it is induced by coercive or deceptive action.” d 287, 289 (Minn. App. 2019) (quotation omitted); (stating that “the government may not produce a plea .

d 712, 716 ( Minn. 1994).

In explaining the validity requirement, the supreme court has stated that “[t]he purpose of the voluntariness requirement is to insure that the defendant is not pleading guilty because of improper pressures.” State v. Trott

The district court is responsible for ensuring that “an adequate factual basis has been established in the record.”

For a guilty plea to be va lid, it must be “accurate, voluntary and intelligent.” (citation omitted).

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

State v. Ecker , State v. Trott , .

A valid guilty plea “must be accurate, voluntary and intelligent (i.e., knowingly and understandingly made).” d 712, 716 (Minn. 1994).

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

Strickland v. 6 Washington, 466 U.S. 668, 687 (1984)

ze the first part of the test —whether counsel’s performance was deficient —under an objective standard of reasonableness; and the second—whether the defense was thereby prejudiced—to determine whether the defendant has shown that “ there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the procee ding would have been different .” Id.; State v. Ecker

13 1987); d 712, 717 Minn. 1994 (suggesting the same standard in reviewing pleas under Norgaard).

without consent or without knowledge of the other person involved.” 2 Under North Carolina v. Alford, 400 U.S. 25, 37, 91 S. Ct. 160, 167 (1970), 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 sta te has sufficient evidence to obtain a conviction.” (citing Alford, 400 U.S. at 37, 91 S. Ct. at 167).

You have continued to blame [the victim] and for 1 “A defendant enters an Alford/Goulette plea if he maintains his innocence but ‘reasonably believes, and the record establishes, the state has sufficie nt evidence to obtain a conviction.’” ( (citing North Carolina v. Alford, 400 U.S. 25, 37, 91 S. Ct. 160, 167 (1970)), review denied (Minn. Sept.

The district court expressed concerns about the plea agreement, stating, 1 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.” State v. Ecker , d 712, 716 (Minn. 1994) (citing Alford, 400 U.S. at 37, 91 S. Ct. at 167).

Under the Strickland test, a petitioner claiming ineffective assistance of counsel arising out of the plea process must show that (1) his attorney’s representation fell below an objective standard of reasonableness and (2) “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” State v. Ecker , (quoting Strickland v. Washington, 466 U.S. 668, 694, 104 S. Ct. 2052, 2068 (1984)).

( ), review denied (Minn. Apr.

See State v. Ecker , d 712, 716 (Minn. 1994).

A guilty plea is invalid if it is not “accurate, voluntary and intelligent.”

The two -prong Strickland standard applies to ineffective - assistance-of-counsel claims, which requires the defendant to (1) “show that counsel’s representation fell below an objective standard of reasonableness” and that (2) “counsel’s deficient performance prejudiced the defense.” State v. Ecker , (quoting Strickland v. Washington, 466 U.S. 668, 687-88, 104 S. Ct. 2052, 2064 (1984)) (other quotation omitted).

d 712, 715-16 (Minn. 1994).

The supreme court has explained that, “[a]lthough the government may not produce a plea through actual or threatened physical harm, or by mental coercion ‘overbearing the will of the defendant,’ a defendant’s motivation to avoid a more serious penalty or set of charges will not invalidate a guilty plea.” State v. Ecker , (applying manifest- injustice standard) (quoting Brady v. United States, 397 U.S. 742, 750, 90 S. Ct. 1463, 1470 (1970)).

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