Cited by
Opinions in Minnesota that cite State v. Trott, 338 N.W.2d 248.
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
The accuracy requirement protects a defendant from “plead ing guilty to a more serious offense than he could be convicted of were he to insist on his right to trial.” Johnson, d at 215 (quoting State v. Trott , (M inn.
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
6 guilty to a more serious offens e than [she] could be convicte d of were [she] to insist on [her] right to trial.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
Moreover, when “[t]he record [] contains a copy of the complaint[, a] defendant, by his plea of guilty, in effect judicially admit[s] the allegations contained in the complaint.”
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A19-1330
Minn. Ct. App. 2020
(rejecting plea-withdrawal argument involving defense counsel’s “unqualified promise of probation” because the signed plea petition and the appellant’s statements at the plea hearing refuted this claim).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
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
- State of Minnesota, Respondent, Minn. Ct. App. 2020
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
This requirement “protect[s] a defendant from pleading guilty to a more serious offense than he could be convicted of were he to insist on his right to trial.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
“The main purpose of the accuracy requirement is to protect a defendant from pleading guilty to a more serious offense than he could be convicted of were he to insist on his right to trial.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
State v. Ecker , State v. Trott , .
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Nathan Christopher Braun, petitioner, Appellant,
Minn. Ct. App. 2020
To be valid, a “plea must be accurate, voluntary, and intelligent.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
“The court should not accept the plea unless the record support s the conclusion that the defendant actually committed an offense at least as serious as the crime to which he is pleading guilty.” -52 (Minn. 1983).
- Lonnie Har Larson, petitioner, Appellant, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
To be valid, a “guilty plea must be accurate, voluntary, and intelligent.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
Lussier, d at 589 ( (permitti ng use of the whole record, including the complaint and photographs)).
- Malik Jordan Olsen, petitioner, Appellant, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
(citing State v. Trott , (permitting use of the whole record, including the complaint and photographs); State v. Hoaglund , n.9 (Minn. 1976) (permitting use of the whole record, including presentence investigation report); (permitting use of presentence in
- Deon Lashawn Mallett, petitioner, Appellant, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
This other evidence can include the criminal complaint because by pleading guilty a defendant “in effect judicially admit[s] the allegations contained in the complaint.” State v. Trott
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
“[T]he plea petition and colloquy may be supplemen ted by other evidence to establish the factual basis for a plea.” (concluding that the record as a whole, which included the complaint and photos of the victim’s injuries taken at the hospital, was sufficient to establish factual basi s for guilty plea); (looking to the record as a whole, including the presentence
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
“The main purpose of the accuracy requ irement is to protect a defendant from pleading guilty to a more serious offense than he could be convicted of were he to insist on his right to trial.” State v. Trott , 4 (Minn. 1983).
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
Second, Dixon cites to State v. Trott to argue that a defendant should be permitted to withdraw a plea when a “promise is unfulfilled.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
(“[T]he plea petition and colloquy may be supplemented by other evidence to establish the factual basis for a plea.”); 3 (complaint and photos of the victim’s injuries); (PSI).
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Berkeley Read Lewis, petitioner, Appellant,
Minn. Ct. App. 2019
See State v. Trott , (concluding that district court did not err in denying plea -withdrawal petition based on court’s reliance on defendant’s plea peti tion and plea over sworn testimony provided at plea-withdrawal hearing).
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
5 By pleading guilty, a defendant “in effect judicially admit[s] the allegations contained in the complaint.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
By pleading guilty, a defendant “in effect judicially admit[s] the allegations contained in the complaint.” 9
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
(citing State v. Trott , d 248, 251 (Minn. 1983)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
In addition to the defendant’s statement, there are other ways to establish a factual basis, including “t estimony of witnesses and statements summarizing the evidence.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
Intelligence Requirement “The purpose of the requirement that the plea be intelligent is to [ensure] that the defendant understands the charges, understands the rights he is waiving by pleading guilty, and understands the consequences of his plea.”
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State of Minnesota, Appellant,
Minn. Ct. App. 2018
(“The record also contains a copy of the complaint and defendant, by his plea of guilty, in effect judicially admitted the allegations contained in the complaint.”).
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Dominique Salatheia Williams, petitioner, Appellant,
Minn. Ct. App. 2018
hat there was no “specific sentencing agreement with the state,” and that the sentencing decision was up to the judge and “could include up to 172 months to serve.” In State v. Trott, the supreme court considered similar circumstances, rejecting the defendant’s claim that he should be permitted to withdraw his guilty plea becaus e defense counsel made an “unqualified promise of probation .”
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
-53 (Minn. 1983) (stating the supreme court is “unwilling to hold that a defendant must be questioned by the [district] court at the time he enters his guilty plea to insure that he understands what the presumptive sentence is under the Minnesota Sentencing Guidelines”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
Other evidence incl udes the complaint since a defendant “by his plea of guilty, in effect judi cially admit[s] the al legations contained in the complaint.”
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Jennifer Natalie Bernard, petitioner, Appellant,
Minn. Ct. App. 2018
“The main purpose of the accuracy requirement is to protect a defendant from pleading guilty to a more serious offense than [she] could be convicted of were [she] to insist on [her] right to trial.”
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
By pleading guilty, a defendant “in effect judicially admit[s] the allegations contained in the complaint.”
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Edson Celin Benitez Dominguez, petitioner, Appellant,
Minn. Ct. App. 2018
“[T]he main purpose of the accuracy requirement is to protect a defendant from pleading guilty to a more serious offense than he could be 14 convicted of were he to insist on his right to trial.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
“The main purpose of the accuracy requirement is to protect a defendant from pleading guilty to a more serious offense than he could be convicted of were he to insist on his right to trial.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
on three separate dates: February 3, 2012, February 5, 2012, and February 7, 2012.” The state argues that because the district court accepted Foss’s guilty pleas, he “in effect judicially admitted the allegations contained in the complaint,” q uoting State v. Trott , , 252 (Minn. 1983).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
11 Intelligence A plea must be intelligent “to insure th at the defendant understands the charges, understands the rights he is waiving by pleading guilty, and understands the consequences of his plea.”
- A17-0435 Minn. Ct. App. 2018
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A17-0708
Minn. Ct. App. 2017
Intelligent and knowing “The purpose of the requirement that the pl ea be intelligent is to insure that the defendant understands the charges, understands the rights he is waiving by pleading guilty, and understands the consequences of his plea.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
The main purpose of the accuracy requirement is to “protect a defendant from plea ding guilty to a more serious offense than he could be convicted of were he to in sist on his right to trial.” State v. Trott
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
This requirement can be satisfied by having the defendant describe the facts constituting the offense, or by other methods, such as “testimony of witnesses and statements summarizing the evidence.” State v. Trott
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
See State v. Trott , (ruling that the factual basis to support a plea to second- degree assault was sufficient on a record th at included the defendant’s admissions, the criminal complaint, and photos of the victim’s injuries).