fair and just standard in Minnesota

2025See, e.g., State v. Theis, 742 N.W.2d 643, 646 (Minn. 2007) (explaining that “manifest injustice exists where a guilty plea is invalid” and that this standard is more demanding than the fair-and-just standard); State v. Wolske, 160 N.W.2d 146, 151 (Minn. 1968) (explaining that a manifest injustice occurs when a defendant is “induced” to plead guilty “by a form of official deceit or by means which are at least grossly unfair”); see also In re Welfare of Child. of M.L.A., 730 N.W.2d 54, 61 (Minn. App. 2007) (explaining that a “manifest injustice certainly includes coercing a parent to admit to a

2017Because the fair-and-just standard is less demanding than the manifest-injustice standard, State v. Theis, 742 N.W.2d 643, 646 (Minn. 2007), if Ellis-Strong shows his plea is invalid, he has shown both a manifest injustice and a fair-and-just reason to withdraw his plea as a matter of law.

2024We review a district court’s denial of a plea-withdrawal motion under the fair-and-just standard for an abuse of discretion, reversing only in the “rare case.” Kim v. State, 434 N.W.2d 263, 266 (Minn. 1989); Raleigh, 778 N.W.2d at 97 .

2024We review a district court’s decision to deny a withdrawal motion under the fair-and-just standard for an abuse of discretion, “reversing only in the ‘rare case.’” Id. (quoting Kim v. State, 434 N.W.2d 263, 266 (Minn. 1989)).

2024We review a district court’s denial of a plea-withdrawal motion under the fair-and-just standard for an abuse of discretion, reversing only in the “rare case.” Kim v. State, 434 N.W.2d 263, 266 (Minn. 1989); Raleigh, 778 N.W.2d at 97 .

2024Raleigh, 778 N.W.2d at 97 . 6 Johnson argues that he satisfied his burden under the fair-and-just standard because the terms of the plea agreement contained a promise that the MCAO would not charge A.A.’s case and the possibility that R.J.’s case would also not be charged.

2025“Even when there is no prejudice to the state, a district court may deny plea withdrawal under rule 15.05, subdivision 2, if the defendant fails to advance valid reasons why withdrawal is fair and just.” State v. Cubas, 838 N.W.2d 220, 224 (Minn. App. 2013), rev. denied (Minn. Dec. 31, 2013); see also id. (characterizing Raleigh as “holding that a district court did not abuse its discretion in denying plea withdrawal under the fair-and-just standard when the prejudice to the state 6 was overstated but the defendant failed to provide any valid reason why withdrawal would be fair and just” (quot

2025“Even when there is no prejudice to the state, a district court may deny plea withdrawal under rule 15.05, subdivision 2, if the defendant fails to advance valid reasons why withdrawal is fair and just.” State v. Cubas, 838 N.W.2d 220, 224 (Minn. App. 2013), rev. denied (Minn. Dec. 31, 2013); see also id. (characterizing Raleigh as “holding that a district court did not abuse its discretion in denying plea withdrawal under the fair-and-just standard when the prejudice to the state 6 was overstated but the defendant failed to provide any valid reason why withdrawal would be fair and just” (quot

2026State v. Lopez, 794 N.W.2d 379, 382 (Minn. App. 2011).

2011See State v. Lopez, 794 N.W.2d 379, 380 (Minn.App.2011) (holding that an unrepresented defendant who entered a plea without signing a written plea petition and who had limited experience with the criminal-justice system satisfied the fair-and-just standard for pre-sentence plea withdrawal).

2017While the fair-and-just standard “is less demanding than the manifest injustice standard,” State v. Theis, 742 N.W.2d 643, 646 (Minn. 2007), a defendant does not have an absolute right to withdraw a plea before sentencing, Kim v. State, 434 N.W.2d 263, 266 (Minn. 1989), and may not withdraw a guilty plea “for simply any reason.” State v. Farnsworth, 738 N.W.2d 364, 372 (Minn. 2007).

2017While the fair-and-just standard “is less demanding than the manifest injustice standard,” State v. Theis, 742 N.W.2d 643, 646 (Minn. 2007), a defendant does not have an absolute right to withdraw a plea before sentencing, Kim v. State, 434 N.W.2d 263, 266 (Minn. 1989), and may not withdraw a guilty plea “for simply any reason.” State v. Farnsworth, 738 N.W.2d 364, 372 (Minn. 2007).

2018The decision whether to permit withdrawal under the fair-and-just standard is within a district court's discretion and "will be reversed only in the rare case in which the appellate court can fairly conclude that the [district] court abused its discretion." State v. Kaiser , 469 N.W.2d 316 , 320 (Minn. 1991) (quotation omitted).

2014State v. Butcher, 563 N.W.2d 776, 780 (Minn. App. 1997), review denied (Minn. Aug. 5, 1997). 11 withdrawal under the fair-and-just standard is within the district court’s sound discretion and will be reversed “only in the rare case in which the appellate court can fairly conclude that the [district] court abused its discretion.” State v. Kaiser, 469 N.W.2d 316, 320 (Minn. 1991).

2026State v. Townsend, 872 N.W.2d 758, 764 (Minn. App. 2015).

2024The fair-and-just standard is “a less demanding standard than the manifest-injustice standard, but it does not permit withdrawal of a guilty plea for simply any reason.” State v. Townsend, 872 N.W.2d 758, 764 (Minn. App. 2015) (quotation omitted).

2026Id. at 782-83 . 6 deny plea withdrawal under the fair-and-just standard even when there is no prejudice to the state, if the defendant fails to show valid reasons to support withdrawal.

2024State v. Jones, 921 N.W.2d 774, 782 (Minn. App. 2018) (quotation omitted), rev. denied (Minn. Feb. 27, 2019).

2017What Thomas is really requesting is an opportunity to have the district court now consider the motion that he withdrew, and he asks that this court remand this case so that the district court can evaluate his motion under the fair-and-just standard.2 We will not 2 Thomas contends that a remand is the remedy that this court provided in Anderson v. State, 746 N.W.2d 901 (Minn. App. 2008).

2015See Anderson v. State, 746 N.W.2d 901, 911 (Minn. App. 2008) (stating that a manifest injustice occurs when a guilty plea is not accurate, voluntary, and intelligent).

2025See, e.g., State v. Theis, 742 N.W.2d 643, 646 (Minn. 2007) (explaining that “manifest injustice exists where a guilty plea is invalid” and that this standard is more demanding than the fair-and-just standard); State v. Wolske, 160 N.W.2d 146, 151 (Minn. 1968) (explaining that a manifest injustice occurs when a defendant is “induced” to plead guilty “by a form of official deceit or by means which are at least grossly unfair”); see also In re Welfare of Child. of M.L.A., 730 N.W.2d 54, 61 (Minn. App. 2007) (explaining that a “manifest injustice certainly includes coercing a parent to admit to a

2025See, e.g., State v. Theis, 742 N.W.2d 643, 646 (Minn. 2007) (explaining that “manifest injustice exists where a guilty plea is invalid” and that this standard is more demanding than the fair-and-just standard); State v. Wolske, 160 N.W.2d 146, 151 (Minn. 1968) (explaining that a manifest injustice occurs when a defendant is “induced” to plead guilty “by a form of official deceit or by means which are at least grossly unfair”); see also In re Welfare of Child. of M.L.A., 730 N.W.2d 54, 61 (Minn. App. 2007) (explaining that a “manifest injustice certainly includes coercing a parent to admit to a

2017State v. Raleigh, 778 N.W.2d 90, 97 (Minn. 2010); State v. Lopez, 794 N.W.2d 379, 382 (Minn. App. 2011). “[A] defendant who can show manifest injustice is entitled as a matter of right to withdraw his plea of guilty.” Hirt v. State, 298 Minn. 553, 557 , 214 N.W.2d 778, 782 (1974).

2017State v. Raleigh, 778 N.W.2d 90, 97 (Minn. 2010); State v. Lopez, 794 N.W.2d 379, 382 (Minn. App. 2011). “[A] defendant who can show manifest injustice is entitled as a matter of right to withdraw his plea of guilty.” Hirt v. State, 298 Minn. 553, 557 , 214 N.W.2d 778, 782 (1974).

2016However, under the fair-and-just standard the state does not need to produce evidence of prejudice where the appellant has failed to advance adequate reasons why granting the plea withdrawal is “fair and just.” Raleigh, 778 N.W.2d at 98.

2016See State v. Abdisalan, 661 N.W.2d 691, 694 (Minn. App. 2003) (affirming district court’s decision to deny plea-withdrawal under the fair-and-just standard where “[n]othing objectively in the record suggests that [defendant] failed to comprehend the nature, purpose, and consequences of his plea”).

2016See State v. Abdisalan, 661 N.W.2d 691, 694 (Minn. App. 2003) (affirming district court’s decision to deny plea-withdrawal under the fair-and-just standard where “[n]othing objectively in the record suggests that [defendant] failed to comprehend the nature, purpose, and consequences of his plea”).

2015See, e.g., State v. Tuttle, 504 N.W.2d 252, 256-57 (Minn. App. 1993) (determining that victim’s recantation of charge did not entitle defendant to withdraw guilty plea under the fair-and-just standard on grounds that plea was based on mistaken belief of strength of state’s case); State v. Risken, 331 N.W.2d 489, 490 (Minn. 1983) (holding that district court did not err in accepting guilty plea despite witness’s recanted testimony because there was a sufficient 5 factual basis for defendant’s guilty plea).

2015See, e.g., State v. Tuttle, 504 N.W.2d 252, 256-57 (Minn. App. 1993) (determining that victim’s recantation of charge did not entitle defendant to withdraw guilty plea under the fair-and-just standard on grounds that plea was based on mistaken belief of strength of state’s case); State v. Risken, 331 N.W.2d 489, 490 (Minn. 1983) (holding that district court did not err in accepting guilty plea despite witness’s recanted testimony because there was a sufficient 5 factual basis for defendant’s guilty plea).

2015“The ultimate decision of whether to allow withdrawal under the fair and just standard is left to the sound discretion of the trial court. . . .” Butala v. State, 664 N.W.2d 333, 338 (Minn. 2003) (quotation omitted).

2014State v. Butcher, 563 N.W.2d 776, 780 (Minn. App. 1997), review denied (Minn. Aug. 5, 1997). 11 withdrawal under the fair-and-just standard is within the district court’s sound discretion and will be reversed “only in the rare case in which the appellate court can fairly conclude that the [district] court abused its discretion.” State v. Kaiser, 469 N.W.2d 316, 320 (Minn. 1991).

2014“A criminal defendant has no absolute right to withdraw a guilty plea once entered.” Perkins v. State, 559 N.W.2d 678, 685 (Minn. 1997). “[T]he Minnesota Rules of Criminal Procedure allow a defendant to seek to withdraw a guilty plea in two 3 Appellant makes these same points concerning his reasons for seeking to withdraw his plea in his pro se supplemental brief. 4 circumstances.” State v. Theis, 742 N.W.2d 643, 646 (Minn. 2007).

2014See State v. Franks, 765 N.W.2d 68, 74 (Minn. 2009) (defining phrase “feel terrorized” as meaning to “feel extreme fear resulting from violence or threats”). 5 DECISION Appellant argues that the district court failed to apply the fair-and-just standard to his presentencing guilty-plea withdrawal motion.