Goulette plea in Minnesota

2024A: No. Q: You don’t believe that if . . . the [s]tate presented evidence in the form of testimony from the officers, 1 “A plea constitutes an Alford/Goulette plea if the defendant maintains innocence but pleads guilty because the record establishes, and the defendant reasonably believes, that the state has sufficient evidence to obtain a conviction.” Williams v. State, 760 N.W.2d 8, 12 (Minn. App. 2009), rev. denied (Minn. Apr. 21, 2009); see North Carolina v. Alford, 400 U.S. 25, 37 (1970); State v. Goulette, 258 N.W.2d 758, 761 (Minn. 1977). 3 squad videos, [Bureau of Criminal Apprehension (

2015A defendant enters an Alford/Goulette plea if he maintains his innocence but “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 , 27 L.Ed.2d 162 (1970)); see also State v. Goulette, 258 N.W.2d 758, 760 (Minn.1977).

2024A: No. Q: You don’t believe that if . . . the [s]tate presented evidence in the form of testimony from the officers, 1 “A plea constitutes an Alford/Goulette plea if the defendant maintains innocence but pleads guilty because the record establishes, and the defendant reasonably believes, that the state has sufficient evidence to obtain a conviction.” Williams v. State, 760 N.W.2d 8, 12 (Minn. App. 2009), rev. denied (Minn. Apr. 21, 2009); see North Carolina v. Alford, 400 U.S. 25, 37 (1970); State v. Goulette, 258 N.W.2d 758, 761 (Minn. 1977). 3 squad videos, [Bureau of Criminal Apprehension (

2015A defendant enters an Alford/Goulette plea if he maintains his innocence but “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 , 27 L.Ed.2d 162 (1970)); see also State v. Goulette, 258 N.W.2d 758, 760 (Minn.1977).

2016“When a defendant enters an Alford/Goulette plea or a Norgaard plea, it is particularly important that a factual basis for the plea be established . . . because in both cases the plea ‘is not supported by the defendant’s admission of guilt.’” Williams, 760 N.W.2d at 12 (quoting State v. Theis, 742 N.W.2d 643, 649 (Minn. 2007)) (citation omitted). [T]he Minnesota Supreme Court has not definitively stated what is required, as opposed to recommended, to establish an adequate factual basis for a Norgaard plea. . . .

2015In fact, an Alford/Goulette plea “is actually contradicted by.his claim of innocence.” Theis, 742 N.W.2d at 649 ; see also Williams, 760 N.W.2d at 12 .

2024A: No. Q: You don’t believe that if . . . the [s]tate presented evidence in the form of testimony from the officers, 1 “A plea constitutes an Alford/Goulette plea if the defendant maintains innocence but pleads guilty because the record establishes, and the defendant reasonably believes, that the state has sufficient evidence to obtain a conviction.” Williams v. State, 760 N.W.2d 8, 12 (Minn. App. 2009), rev. denied (Minn. Apr. 21, 2009); see North Carolina v. Alford, 400 U.S. 25, 37 (1970); State v. Goulette, 258 N.W.2d 758, 761 (Minn. 1977). 3 squad videos, [Bureau of Criminal Apprehension (

2016“When a defendant enters an Alford/Goulette plea or a Norgaard plea, it is particularly important that a factual basis for the plea be established . . . because in both cases the plea ‘is not supported by the defendant’s admission of guilt.’” Williams, 760 N.W.2d at 12 (quoting State v. Theis, 742 N.W.2d 643, 649 (Minn. 2007)) (citation omitted). [T]he Minnesota Supreme Court has not definitively stated what is required, as opposed to recommended, to establish an adequate factual basis for a Norgaard plea. . . .

2016In two circumstances, however, “a factual basis must be established by other means: when a defendant enters an Alford/Goulette plea and when a defendant enters a Norgaard plea.” Id.

2016See State v. Ecker, 524 N.W.2d 712, 716-17 (Minn. 1994) (explaining that a district court may accept a Norgaard or Alford/Goulette plea if there is an adequate factual basis and the defendant understands his or her rights).

2017“In two circumstances, however, a factual basis must be established by other means: when a defendant enters an Alford/Goulette plea and when a defendant enters a Norgaard plea.” Johnson, 867 N.W.2d at 215 (quotation omitted).

2016Affirmed. 2 “The means of ensuring the factual basis of an Alford/Goulette plea are essentially the same as the means of ensuring the factual basis of a Norgaard plea.” Johnson, 867 N.W.2d at 215 .

1997Compare Shorter, 511 N.W.2d at 746-47 (recognizing that manifest injustice required withdrawal of the guilty plea under the “highly unusual facts of this case” due to incomplete police investigation, defense counsel's inability to locate corroborating witnesses, sentencing court’s failure to question the defendant at the plea hearing and acceptance of the plea based on leading questions, and postconviction court's failure to conduct an evidentiary hearing) with Kim v. State, 434 N.W.2d 263, 266 (Minn.1989) (holding that the defendant, who was questioned thoroughly about the consequences of ent