record of the plea hearing in Minnesota

2016Our de novo review focuses on whether the record shows “a strong factual basis for the plea and [that] the defendant clearly expressed his desire to enter the plea based on his belief that the State’s evidence would be sufficient to convict him.” Theis, 742 N.W.2d at 647 (quotation omitted).

2015A 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.” Ecker, 524 N.W.2d at 716 (citing North Carolina v. Alford, 400 U.S. 25, 37 , 91 S. Ct. 160, 167 (1970)). “[C]areful 2 scrutiny of the factual basis for the plea is necessary within the context of an Alford plea because of the inherent conflict in pleading guilty while maintaining innocence.” State v. Theis, 742 N.W.2d 643, 648-49 (Minn. 2007).

2017When “the factual basis of a guilty plea is challenged on direct appeal, this court conducts a de novo review by reviewing the record of the plea hearing, which should reveal the factual basis.” State v. Johnson, 867 N.W.2d 210, 216 (Minn. App. 2015), review denied (Minn. Sept. 29, 2015).

2016However, “[i]f the factual basis of a guilty plea is challenged on direct appeal, this court conducts a de novo review by reviewing the record of the plea hearing, which should reveal the factual 1 Hough does not assign error to the district court’s post-plea receipt of the police reports. 9 basis.” State v. Johnson, 867 N.W.2d 210, 216 (Minn. App. 2015), review denied (Minn. Sept. 29, 2015).

2015See Raleigh, 778 N.W.2d at 94 ; Brown, 449 N.W.2d at 182 .

2014Raleigh, 778 N.W.2d at 94 .

2015A 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.” Ecker, 524 N.W.2d at 716 (citing North Carolina v. Alford, 400 U.S. 25, 37 , 91 S. Ct. 160, 167 (1970)). “[C]areful 2 scrutiny of the factual basis for the plea is necessary within the context of an Alford plea because of the inherent conflict in pleading guilty while maintaining innocence.” State v. Theis, 742 N.W.2d 643, 648-49 (Minn. 2007).

2014See State v. Ecker, 524 N.W.2d 712, 716 (Minn. 1994).

2017“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.” State v. Trott, 338 N.W.2d 248, 251 (Minn. 1983).

2015In Padilla, the Supreme Court held that the Sixth Amendment requires that defense counsel provide legal advice regarding the immigration consequences of a defendant’s guilty plea. 130 S. Ct. at 1482, 1486 .

2015A 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.” Ecker, 524 N.W.2d at 716 (citing North Carolina v. Alford, 400 U.S. 25, 37 , 91 S. Ct. 160, 167 (1970)). “[C]areful 2 scrutiny of the factual basis for the plea is necessary within the context of an Alford plea because of the inherent conflict in pleading guilty while maintaining innocence.” State v. Theis, 742 N.W.2d 643, 648-49 (Minn. 2007).

2015A 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.” Ecker, 524 N.W.2d at 716 (citing North Carolina v. Alford, 400 U.S. 25, 37 , 91 S. Ct. 160, 167 (1970)). “[C]areful 2 scrutiny of the factual basis for the plea is necessary within the context of an Alford plea because of the inherent conflict in pleading guilty while maintaining innocence.” State v. Theis, 742 N.W.2d 643, 648-49 (Minn. 2007).

2014See Phipps, 820 N.W.2d at 286 .

2014See Egge, 611 N.W.2d at 575 .

2014Independent Analysis of Factual Basis by District Court To ensure that an Alford plea meets the accuracy requirement of a valid plea, the district court must analyze the factual basis offered for the plea and reasonably and “independently conclude that there is a strong probability that the defendant would be found guilty of the charge to which he pleaded guilty, notwithstanding his claims of innocence.” Theis, 742 N.W.2d at 647 , 649 (citing Goulette, 258 N.W.2d at 758, 760 ).

2014See id.