Cited by

v. Jones, -53 (Minn. 2003) (concluding district court’s imposition of mandatory-conditional release term does not require any additional fact finding); -49 (Minn. 2001) (holding defendant’s due-process rights were not violated when district court amended defendant’s sentence to include conditional-release term) ; -45 (Minn. 2000) (determining that sentencing court must either modify sentence or allow guilty plea to be withdrawn when defendant is subject to mandatory conditional release that effe

(defendant pleaded guilty without awareness that there would be additional period of conditional release after incarceration); (defendant pleaded guilty based on lower criminal-history score than was correct)

- 25 (Minn. 2003) (allowing for withdrawal of plea when the district court amended the initial sentencing order to impose a period of conditional release that was not included in the plea 12 petition or mentioned at the initia l sentencing hearing); State v. Jumping Eagle , 45 (Minn. 2000) ( allowing for withdrawal of plea when the district court amended the initial sentencing order to impose a conditional release that was not included in the plea petition and was not imposed at the initial sent

ce remained less than the maximum sentence contemplated in the plea agreement); Rhodes, d at 326 (“In situations where the addition of the conditional release term would result in a sentence that exceeded the maximum executed sentence agreed to in the plea bargain, we have held that the addition of the conditional release term violates the plea agreement.”); (holding that the later imposition of a conditional -release term rendered defendant’s plea invalid because the additional sentence exceede

See, (remanding to permit withdrawal of a guilty plea or re sentencing where the de fendant was mistaken that the offense was not subject to a mandatory conditional release term); (remanding to permit withdrawal of a guilty plea where the defendant mis

Inducing a guilty plea “by promises that cannot be fulfilled invalidates the plea.”

In State v. Jumping Eagle , the supreme court again considered similar circumstances and held that, on remand, the state should be allowed to present argument to the district court as to whether plea withdrawal or sentence modification was the most appropriate remedy.

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

James v. State , State v. Jumping Eagle

Additionally, “[i]nducement of a guilty plea by promises that cannot be fulfilled invalidates the plea.”

(holding that on remand the district court must either allow plea withdrawal, or sentence in comp liance with the 7 original plea agreement); (noting that if a defendant does not receive the benefit of his plea bargain on remand, he is entitle

Kendricks’s reliance on James v. State , 730 (Minn. 2005), d 879, 882 (Minn. 1998), is misplaced.

“Inducement of a guilty plea by promises that cannot be fulfilled invalidates the plea; possible remedies include requiring performance of the agreement, altering the sentence, or allowing the plea to be withdrawn.” (stating 13 that plea withdrawal may be appropriate where an unqualified promise in a plea agreement is dishonored but not where the defendant merely “has not achieved an unwarranted hope” (qu

Maddox argues that his guilty plea was not voluntary because it was “induced by the district court’s refusal to consider his pro se motions.” “The voluntariness requirement insures that the guilty plea is not in response to improper pressures or inducements.” (quotation omitted).

See, e.g., James, d at 725-26, 730; 526-29 (Minn. 2003); -45 (Minn. 2000); -82 (Minn. 1998).

before sentencing); Wukawitz, d at 526, 528-29 (holding that a guilty plea induced by a promise of a maximum definite sentence that is later increased by a conditional-release term requires that the defendant have the opportunity to withdraw the guilty plea or be granted a modified sentence, if withdrawal of the guilty plea would unduly prejudice the state); -45 (Minn. 2000) (stating that the defendant agreed to a maximum sentence of 172 months and, because the defendant was not informed of the

(holding that plea withdrawal should be the first option, but if the state would be unduly prejudiced by withdrawal, the district court may modify the sentence); (remanding for the district court to either allow appellant to withdraw his plea or to modify his sentence to the agreed-upon sentence); (holding that appellant must be allowed to withdraw from the plea agreement if he so chooses, but if he does no

ea bargain.” Id.; cf. James, d at 726, 730 (concluding that defendant was entitled to plea withdrawal or sentence modification where district court failed to inform him about conditional-release term at either plea hearing or sentencing hearing and failed to 7 impose conditional-release term at time of sentencing); 45 (Minn. 2000) (concluding that defendant was entitled to plea withdrawal or sentence modification where “mandatory conditional-release term was not mentioned at [defendant]’s senten

(“Inducement of a guilty plea by promises that cannot be fulfilled invalidates the plea .

(invalidating sentence based on plea agreement induced by incorrect belief of maximum sentence).

-20 (Minn.2003); -73 (Minn.2000)