factual basis requirement (North Dakota) · Go Syfert
← North Dakota issues

factual basis requirement in North Dakota

6 North Dakota opinions name it 1 courts 1982–2012 0 in the last five years

The cases below were cited by North Dakota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
Miller Enterprises, Inc. v. Dog N' Cat Pet Centers of America, Inc.green
nd · 1989 · cited in 2 North Dakota opinions naming this issue, 1994–1994
2 sentences

1994Miller Enterprises v. Dog N’ Cat Pet Centers, 447 N.W.2d 639, 643 (N.D.1989).

1994Miller Enterprises v. Dog N' Cat Pet Centers, 447 N.W.2d 639, 643 (N.D.1989).

22
James Godwin v. United Statesgreen
ca2 · 1982 · cited in 1 North Dakota opinions naming this issue, 2012–2012
1 sentence

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

11
United States v. Kenneth Hart Adams, Howard Willisgreen
ca2 · 2006 · cited in 1 North Dakota opinions naming this issue, 2012–2012
1 sentence

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

11
Pablo Carreon v. United Statesgreen
ca7 · 1978 · cited in 1 North Dakota opinions naming this issue, 2012–2012
1 sentence

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

11
United States v. Perry D. McCrearygreen
ca6 · 2007 · cited in 1 North Dakota opinions naming this issue, 2012–2012
1 sentence

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

11
Comstock v. Stategreen
indctapp · 1981 · cited in 1 North Dakota opinions naming this issue, 1982–1982
1 sentence

1982See, e.g., United States v. Davis, 516 F.2d 574, 578 (7th Cir.1975) [“The requirement that there be a factual basis for the plea is satisfied, ... despite the defendant’s denial of guilt, if the judge determines from the prosecutor’s recital of the evidence the government will offer that proof of guilt is strong.”]; State v. Norman, 118 Ariz. 23 , 574 P.2d 491, 492-493 (Ariz.Ct.App.1978) [recitation of evidence by prosecutor, concurred in by defense counsel, adequate to establish factual basis for plea]; Comstock v. State, Ind. App., 422 N.E.2d 395, 399 (1981) [prosecutor’s detailed recitation

11
United States v. Robert George Beckgreen
ca8 · 1979 · cited in 1 North Dakota opinions naming this issue, 1982–1982
1 sentence

1982See, e.g., United States v. Davis, 516 F.2d 574, 578 (7th Cir.1975) [“The requirement that there be a factual basis for the plea is satisfied, ... despite the defendant’s denial of guilt, if the judge determines from the prosecutor’s recital of the evidence the government will offer that proof of guilt is strong.”]; State v. Norman, 118 Ariz. 23 , 574 P.2d 491, 492-493 (Ariz.Ct.App.1978) [recitation of evidence by prosecutor, concurred in by defense counsel, adequate to establish factual basis for plea]; Comstock v. State, Ind. App., 422 N.E.2d 395, 399 (1981) [prosecutor’s detailed recitation

11
State v. Mortrudgreen
nd · 1981 · cited in 1 North Dakota opinions naming this issue, 1982–1982
2 sentences

1982In the instant case [McKay ] defendant merely claims no recollection.” Although our court has never discussed the specific procedures necessary to satisfy the factual basis requirement for an Alford plea, we recently stated, in State v. Mortrud, 312 N.W.2d 354, 357 (N.D.1981), a case expressly limited to its own facts and circumstances, that: “Rule 11 requires the court to address the defendant personally in order to determine the factual basis for the guilty plea and to assure that it is knowing and voluntary.” At first glance it would appear that our statement in Mortrud, supra, that a court

1982In the instant case [McKay ] defendant merely claims no recollection.” Although our court has never discussed the specific procedures necessary to satisfy the factual basis requirement for an Alford plea, we recently stated, in State v. Mortrud, 312 N.W.2d 354, 357 (N.D.1981), a case expressly limited to its own facts and circumstances, that: “Rule 11 requires the court to address the defendant personally in order to determine the factual basis for the guilty plea and to assure that it is knowing and voluntary.” At first glance it would appear that our statement in Mortrud, supra, that a court

11
State v. Johnsongreen
wisctapp · 1981 · cited in 1 North Dakota opinions naming this issue, 1982–1982
2 sentences

1982See, e.g., United States v. Davis, 516 F.2d 574, 578 (7th Cir.1975) [“The requirement that there be a factual basis for the plea is satisfied, ... despite the defendant’s denial of guilt, if the judge determines from the prosecutor’s recital of the evidence the government will offer that proof of guilt is strong.”]; State v. Norman, 118 Ariz. 23 , 574 P.2d 491, 492-493 (Ariz.Ct.App.1978) [recitation of evidence by prosecutor, concurred in by defense counsel, adequate to establish factual basis for plea]; Comstock v. State, Ind. App., 422 N.E.2d 395, 399 (1981) [prosecutor’s detailed recitation

1982See, e.g., United States v. Davis, 516 F.2d 574, 578 (7th Cir.1975) [“The requirement that there be a factual basis for the plea is satisfied, ... despite the defendant’s denial of guilt, if the judge determines from the prosecutor’s recital of the evidence the government will offer that proof of guilt is strong.”]; State v. Norman, 118 Ariz. 23 , 574 P.2d 491, 492-493 (Ariz.Ct.App.1978) [recitation of evidence by prosecutor, concurred in by defense counsel, adequate to establish factual basis for plea]; Comstock v. State, Ind. App., 422 N.E.2d 395, 399 (1981) [prosecutor’s detailed recitation

11
State v. Normangreen
arizctapp · 1978 · cited in 1 North Dakota opinions naming this issue, 1982–1982
2 sentences

1982See, e.g., United States v. Davis, 516 F.2d 574, 578 (7th Cir.1975) [“The requirement that there be a factual basis for the plea is satisfied, ... despite the defendant’s denial of guilt, if the judge determines from the prosecutor’s recital of the evidence the government will offer that proof of guilt is strong.”]; State v. Norman, 118 Ariz. 23 , 574 P.2d 491, 492-493 (Ariz.Ct.App.1978) [recitation of evidence by prosecutor, concurred in by defense counsel, adequate to establish factual basis for plea]; Comstock v. State, Ind. App., 422 N.E.2d 395, 399 (1981) [prosecutor’s detailed recitation

1982See, e.g., United States v. Davis, 516 F.2d 574, 578 (7th Cir.1975) [“The requirement that there be a factual basis for the plea is satisfied, ... despite the defendant’s denial of guilt, if the judge determines from the prosecutor’s recital of the evidence the government will offer that proof of guilt is strong.”]; State v. Norman, 118 Ariz. 23 , 574 P.2d 491, 492-493 (Ariz.Ct.App.1978) [recitation of evidence by prosecutor, concurred in by defense counsel, adequate to establish factual basis for plea]; Comstock v. State, Ind. App., 422 N.E.2d 395, 399 (1981) [prosecutor’s detailed recitation

11
United States v. Eddie Lee Davis, A/K/A Big Daddygreen
ca7 · 1975 · cited in 1 North Dakota opinions naming this issue, 1982–1982
1 sentence

1982See, e.g., United States v. Davis, 516 F.2d 574, 578 (7th Cir.1975) [“The requirement that there be a factual basis for the plea is satisfied, ... despite the defendant’s denial of guilt, if the judge determines from the prosecutor’s recital of the evidence the government will offer that proof of guilt is strong.”]; State v. Norman, 118 Ariz. 23 , 574 P.2d 491, 492-493 (Ariz.Ct.App.1978) [recitation of evidence by prosecutor, concurred in by defense counsel, adequate to establish factual basis for plea]; Comstock v. State, Ind. App., 422 N.E.2d 395, 399 (1981) [prosecutor’s detailed recitation

11
State v. Goulettegreen
minn · 1977 · cited in 1 North Dakota opinions naming this issue, 1982–1982
1 sentence

1982See, e.g., United States v. Davis, 516 F.2d 574, 578 (7th Cir.1975) [“The requirement that there be a factual basis for the plea is satisfied, ... despite the defendant’s denial of guilt, if the judge determines from the prosecutor’s recital of the evidence the government will offer that proof of guilt is strong.”]; State v. Norman, 118 Ariz. 23 , 574 P.2d 491, 492-493 (Ariz.Ct.App.1978) [recitation of evidence by prosecutor, concurred in by defense counsel, adequate to establish factual basis for plea]; Comstock v. State, Ind. App., 422 N.E.2d 395, 399 (1981) [prosecutor’s detailed recitation

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in North Dakota. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Eaton v. State green
nd · 2011
1 sentence

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

12012–2012
Patten v. State green
nd · 2008
2 sentences

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

12012–2012
Eaton v. State green
nd · 2011
1 sentence

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

12012–2012
McCarthy v. United States green
scotus · 1969
2 sentences

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

2012United States v. Adams, 448 F.3d 492, 502 (2nd Cir.2006) (“ ‘Such defects are not technical, but are so fundamental as to cast serious doubt on the voluntariness of the plea,’ ... and require reversal and remand so that the defendant may plea anew or stand trial.”) (quoting Godwin v. United States, 687 F.2d 585, 591 (2nd Cir.1982)); United States v. McCreary-Redd, 475 F.3d 718, 726 (6th Cir.2007) (concluding “the district court’s failure to establish a factual basis ... affected [the defendant’s] substantial rights”); Carreon v. United States, 578 F.2d 176, 179 (7th Cir.1978) (stated that “[w]

12012–2012
State v. Steen green
nd · 2004
2 sentences

2007I [¶ 2] The underlying factual basis for this appeal is set forth in State v. Steen, 2004 ND 228 , 690 N.W.2d 239 (“Steen I”) and State v. Steen, 2005 ND 199 , 709 N.W.2d 21 (“Steen II), and will not be repeated here except as necessary to assist in resolving the issues raised in this appeal.

2007I [¶ 2] The underlying factual basis for this appeal is set forth in State v. Steen, 2004 ND 228 , 690 N.W.2d 239 (“Steen I”) and State v. Steen, 2005 ND 199 , 709 N.W.2d 21 (“Steen II), and will not be repeated here except as necessary to assist in resolving the issues raised in this appeal.

12007–2007
State v. Steen neutral
nd · 2005
1 sentence

2007I [¶ 2] The underlying factual basis for this appeal is set forth in State v. Steen, 2004 ND 228 , 690 N.W.2d 239 (“Steen I”) and State v. Steen, 2005 ND 199 , 709 N.W.2d 21 (“Steen II), and will not be repeated here except as necessary to assist in resolving the issues raised in this appeal.

12007–2007
Johnson v. State green
nd · 2005
1 sentence

2007I [¶ 2] The underlying factual basis for this appeal is set forth in State v. Steen, 2004 ND 228 , 690 N.W.2d 239 (“Steen I”) and State v. Steen, 2005 ND 199 , 709 N.W.2d 21 (“Steen II), and will not be repeated here except as necessary to assist in resolving the issues raised in this appeal.

12007–2007
State v. Lueder green
nd · 1977
2 sentences

2001The appointment of counsel may be necessary for proper investigation of the factual basis for a claim by an incarcerated applicant, and as we indicated in Lueder, 252 N.W.2d at 865-66 , trial courts should attempt to make post-conviction hearings meaningful by considering appointing counsel to represent an indigent applicant who is unable to attend the hearing because of confinement. [¶ 21] Here, however, we are presented with the exceptional situation in which it was appropriate for the trial court not to appoint counsel for Bell.

2001The appointment of counsel may be necessary for proper investigation of the factual basis for a claim by an incarcerated applicant, and as we indicated in Lueder, 252 N.W.2d at 865-66 , trial courts should attempt to make post-conviction hearings meaningful by considering appointing counsel to represent an indigent applicant who is unable to attend the hearing because of confinement. [¶ 21] Here, however, we are presented with the exceptional situation in which it was appropriate for the trial court not to appoint counsel for Bell.

12001–2001

Where else courts name it

TX 368 (1962–2026) IL 218 (1969–2026) CA 136 (1954–2026) MA 92 (1990–2026) MS 72 (1992–2025) MI 71 (1971–2026) WI 43 (1968–2025) NJ 39 (1981–2026) WA 37 (1976–2026) MN 34 (1978–2026) NY 31 (1968–2026) IA 28 (1980–2022) PA 25 (1973–2023) FL 23 (1974–2025) MO 22 (1974–2022) ID 19 (1985–2026) IN 18 (1990–2026) CT 17 (1987–2021) TN 16 (1994–2020) VT 15 (1978–2026) OR 14 (1974–2024) MD 13 (1987–2025) KS 13 (1993–2022) OK 13 (1988–2023) GA 10 (1988–2026) SD 10 (1987–2016) WY 9 (1989–2023) NH 8 (2011–2025) DC 8 (1974–2024) AZ 7 (1977–2018) DE 7 (2001–2015) OH 7 (2004–2023) NM 6 (1976–2019) UT 6 (1984–2023) ND 6 (1982–2012) AK 5 (1998–2025) LA 5 (1975–2008) AR 5 (1987–2016) ME 4 (1983–2008) NE 4 (2017–2026) AL 4 (1988–2026) NV 4 (2014–2018) SC 4 (2012–2022) WV 4 (1936–2025) NC 3 (2012–2022) CO 3 (1993–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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