Cited by
Opinions in Minnesota that cite State v. Iverson, 664 N.W.2d 346.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
omplaint as an additional factual basis for Sanchez’s guilty plea “with the limitation reflected in the objection from [defense counsel].” It is true, as Sanchez argues, that a guilty plea’s factual basis “is inadequate when the defendant makes statements that negate an essential element of the charged crime because such statements are inconsistent with a plea of guilty.”
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Ronald Lee Schober, petitioner, Appellant,
Minn. Ct. App. 2026
d 391, 394 , 396, 399 (Minn. 2024) (citing State v. Iverson , d 346, 350 (Minn. 2003) for the proposition that, for a guilty plea to be accepted, any statement of the defendant that negates an element of the crime must be withdrawn or corrected).
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Alexis Lashun Suggs, petitioner, Appellant,
Minn. Ct. App. 2026
Suggs argues that his guilty plea to domestic assault was inaccurate and, therefore, invalid.1 For a plea to be accurate, it must be supported by a proper factual basis, with “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” (quotation omitted).
- State of Minnesota v. Joseph Robert Clay Minn. Ct. App. 2026
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State of Minnesota v. Joseph Robert Clay
Minn. Ct. App. 2026
For a guilty plea to be accurate, it must be supported by a proper factual basis, with “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which [the defendant] desires to plead guilty.” -50 (Minn. 2003) (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2026
- State of Minnesota v. James Allan Denker Minn. Ct. App. 2026
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State of Minnesota v. James Allan Denker
Minn. Ct. App. 2026
(-50 (Minn. 2003)), rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
The factual basis must provide “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” State 8 v. Iverson, (quotation omitted).
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Reginald Scott Hubbard, petitioner, Appellant,
Minn. Ct. App. 2025
“To be accurate, a plea must be established on a proper factual basis,” Raleigh, d at 94, which requires “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty,” (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2025
- In the Matter of the Welfare of: T. J. D., Child. Minn. Ct. App. 2025
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Distinguished
State of Minnesota, Respondent,
Minn. Ct. App. 2025
“[A] factual basis is inadequate when the defendant makes statements that negate an essential element of the charged crime because such statements are inconsistent with a plea of guilty .” State v. Iverson , (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
A proper factual basis exists if there are “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” (quotation omitted).
- State of Minnesota, Respondent, vs. Matthew Douglas Paulson, Appellant Minn. 2025
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State of Minnesota, Respondent, vs. Matthew Douglas Paulson, Appellant
Minn. 2025
5 5 In a few of our decisions, we have framed the factual basis requirement as demanding “evidence that the defendant’s conduct meets all elements of the offense to which he is pleading guilty.” See, (emphasis added) ( (stating that “[t]he factual basis of a plea is inadequate when the defendant makes statements that negate an essential element of the charged crime because such statements are inconsistent with a plea of guilty”)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
A factual basis is inadequate if “the defendant makes statements that negate an essential element of the charged crime,” unless 9 the guilty plea is rehabilitated.
- 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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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Pertinent to this case, a plea’s factual basis “is inadequate when the defendant makes statements that negate an essential element of the charged crime because such statements are inconsistent with a plea of guilty.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
For a guilty plea to be accurate, “there must be sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” (quotation omitted).
- Connor Jerome Eischens, petitioner, Appellant, Minn. Ct. App. 2024
- Abdullahi Aden Ibrahim v. State of Minnesota Minn. Ct. App. 2024
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Abdullahi Aden Ibrahim v. State of Minnesota
Minn. Ct. App. 2024
For a plea to be accurate, a plea 4 must be supported by a proper factual basis, with “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charges to which he desires to plead guilty.” -50 (Minn. 2003) (quotation omitted).
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Emmanuel J Woart, petitioner, Appellant,
Minn. Ct. App. 2024
To satisfy the accuracy requirement, a plea must be supported by a proper factual basis, with “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” State v. Iverson , -50 (Minn. 2003) (quotation omitted).
- State of Minnesota v. Sylvester Jones 7 N.W.3d 391 Minn. 2024
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State of Minnesota v. Sylvester Jones
7 N.W.3d 391
Minn. 2024
A factual basis is inadequate, though, “when the defendant makes statements that negate an essential element of the charged crime,” unless the defendant subsequently withdraws or corrects the statement, or the guilty plea is otherwise rehabilitated.
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
A proper factual basis exists if there are 5 “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” (quotation omitted).
- A23-0027 State of Minnesota v. Eric Dow Johnson Minn. Ct. App. 2024
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A23-0027 State of Minnesota v. Eric Dow Johnson
Minn. Ct. App. 2024
(stating a defendant is free 5 to appeal from a judgment of conviction and argue that the record at the time of the plea was inadequate); (), rev. denied (Minn. Sept.
- State of Minnesota v. Devin Lee Arola Johnson Minn. Ct. App. 2023
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State of Minnesota v. Devin Lee Arola Johnson
Minn. Ct. App. 2023
at 182; -55 (Minn. 2003).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
The defendant’s admissions at the plea hearing must “support a conclusion that [his] conduct falls within the charge to which he desires to plead guilty.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
Jones also argues that his plea is inaccurate because he uttered a statement of innocence during the prosecutor’s enhanceability inquiry.2 W hen a defendant denies an essential element of an offense or states a fact that is inconsistent with the facts necessary to establish an essential element of the offense during the plea colloquy, the factual basis is inadequate , unless the defendant subsequently corrects the statement and admits the necessary facts or the record otherwise establishes guilt
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
The defendant’s testimony must “support a conclusion that [the] defendant’s conduct falls within the charge to which he desires to plead guilty,” and therefore, a guilty plea is invalid as inaccurate if the defendant’s testimony “negate[s] an essential element of the charged crime.” -50 (Minn. 2003) (quotation omitted).
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Deshon Israel Bonnell,
Minn. 2022
State v. Iverson , –50 (Minn. 2003); (holding that a guilty plea was inadequate when the defendant’s plea indicated that he did not “know” about the predatory registration requirement, thus negating the “knowingly” element of the crime).
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Matthew Howard Isensee, petitioner, Appellant,
Minn. Ct. App. 2022
“The factual basis of a plea is inadequate when the defendant makes statements that negate an essential element of the charged crime because such statements are inconsistent with a plea of guilty.”
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State of Minnesota,
Minn. 2022
(stating that a defendant “is free to simply appeal directly from a judgment of conviction and contend that the record made at the time the plea was entered is inadequate” ).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
“For a guilty plea to be accurate, a factual basis must be established showing that the defendant’s conduct meets all elements of the offense to which he is pleading guilty.” Jones, d at 779; -50 (Minn. 2003).
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Nicholas Patrick Pankuch, petitioner, Appellant,
Minn. Ct. App. 2022
A proper factual basis exists if there are “‘sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.’” (quoting Kelsey v. State , ).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
27, 2019); see also State v. Iverson , -50 (Minn. 2003).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
4 A guilty plea is accurate if there are “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” -50 (Minn. 2003) (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
In turn, a plea is supported by a proper factual basis if there are “sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” State v. Iverson , 9 (Minn. 2003) (quo tation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
“For a guilty plea to be accurate, a factual basis must be established showing that the defendant’s conduct meets all elements of the offense to which he is pleading guilty.” Jones, d at 779; see also State v. Iverson , -50 (Minn. 2003).
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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State of Minnesota,
Minn. 2021
“Accuracy requires that the plea be supported by a proper factual basis, that there must be sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” State v. Iverson , (citation omitted) (internal quotation marks omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
A factual basis “is inadequate when the defendant makes statements that negate an essential element of the charged crime because such statements are inconsistent with a plea of guilty.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
“A ccuracy requires that the plea be supported by a proper factual basis[:] that there must be sufficient facts on the record to support a conclusion that defendant’s conduct falls within the charge to which he desires to plead guilty.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
When a defendant “makes statements that negate an essential element of the charged crime,” the plea is inadequate “because such statements are inconsistent with a plea of guilty.”