manifest injustice standard in Minnesota

2024McDonald argues that his plea was involuntary and that he should be allowed to withdraw it under the manifest-injustice standard. “[M]anifest injustice exists where a guilty plea is invalid.” State v. Theis, 742 N.W.2d 643, 646 (Minn. 2007).

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.

2016We review the denial of a plea-withdrawal motion under the manifest injustice standard de novo because “[a]ssessing the validity of a plea presents a question of law.” Id.

2016Our review of a district court’s denial of a guilty-plea withdrawal motion under the manifest-injustice standard inquires whether appellant demonstrated that the guilty- plea was invalid, i.e., not accurate, voluntary, and intelligent, which is “a question of law that we review de novo.” Raleigh, 778 N.W.2d at 94 .

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).

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).

2016A guilty plea is invalid if it is not “accurate, voluntary, and intelligent.” Perkins v. State, 559 N.W.2d 678, 688 (Minn. 1997).

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).

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).

2025State v. Lopez, 794 N.W.2d 379, 382 (Minn. 2011).

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).

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).

2014Fair-and-Just Standard Yang argues that the district court erroneously applied only the manifest-injustice standard and did not consider his motion to withdraw the plea under the fair-and-just standard. “[T]he ‘ultimate decision’ of whether to allow withdrawal under the ‘fair and just’ standard is ‘left to the sound discretion of the [district] court, and it 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) (quoting Kim v. State, 434 N.W.2d 265 , 266 (Minn.

2008And the supreme court has noted the distinction, stating that the fair-and-just standard “is less demanding than the manifest injustice standard.” State v. Theis, 742 N.W.2d 643, 646 (Minn.2007); see also State v. Kaiser, 469 N.W.2d 316, 319 (Minn.1991) (explaining that the right to withdraw a plea for a manifest injustice applies before or after sentencing but that a district court may allow withdrawal before sentencing on the lesser showing of a fair and just reason to withdraw).

2026Id.; Dikken v. State, 896 N.W.2d 873, 879 (Minn. 2017).

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

2025Id. at 308 (quotation omitted); Minn. 3 Jama also invokes the manifest-injustice standard in his brief, but he does not clearly apply that standard in his arguments.

2017Weitzel v. State, 883 N.W.2d 553, 556 (Minn. 2016).

2016To be valid, a guilty plea “must be accurate, voluntary and intelligent.” State v. Trott, 338 N.W.2d 248, 251 (Minn. 1983).

2016See State v. Carver, 577 N.W.2d 245 , 251 n.5 (Minn. App. 1998) (declining to consider a theory on appeal that appellant did not argue).

2016See Carey v. State, 765 N.W.2d 396, 400 (Minn. App. 2009) (reviewing postconviction court’s application of manifest-injustice standard for abuse of discretion), review denied (Minn. Aug. 11, 2009).

2011See, e.g., Vernlund v. State, 589 N.W.2d 307, 310-11 (Minn.App.1999) (holding plea invalid because court did not question defendant to establish factual basis as rule 15.02 requires).

2008See United States v. Seharf, 568 F.2d 106 , 107-08 n. 2 (8th Cir.1978) (noting that the fair-and-just standard is lesser than the manifest-injustice standard); see also United States v. Farley, 72 F.3d 158, 162 (D.C.Cir.1995) (noting that after sentencing a defendant must meet a more stringent standard than the more lenient fair-and-just standard).

2008See United States v. Seharf, 568 F.2d 106 , 107-08 n. 2 (8th Cir.1978) (noting that the fair-and-just standard is lesser than the manifest-injustice standard); see also United States v. Farley, 72 F.3d 158, 162 (D.C.Cir.1995) (noting that after sentencing a defendant must meet a more stringent standard than the more lenient fair-and-just standard).

1998Where a determination of manifest injustice is not made as a matter of law, as in the case of a constitutional violation or a breach of a plea agreement by the state, the plain meaning of the phrase indicates that a determination must be an equitable balancing of interests based on the totality of the circumstances. *98 Cf. People v. Kadadu, 169 Mich.App. 278 , 425 N.W.2d 784, 787 (1988) (finding no abuse of discretion where district court, on equitable grounds, allowed defendant who had not been informed of immigration consequences to withdraw plea).

1998Where a determination of manifest injustice is not made as a matter of law, as in the case of a constitutional violation or a breach of a plea agreement by the state, the plain meaning of the phrase indicates that a determination must be an equitable balancing of interests based on the totality of the circumstances. *98 Cf. People v. Kadadu, 169 Mich.App. 278 , 425 N.W.2d 784, 787 (1988) (finding no abuse of discretion where district court, on equitable grounds, allowed defendant who had not been informed of immigration consequences to withdraw plea).

1994ANALYSIS Minn.R.Crim.P. 15.07 permits the district court to accept a guilty plea to a lesser offense, without the prosecution’s consent, provided “that it would be a manifest injustice not to accept the plea.” The manifest injustice requirement properly applies to situations like a dishonored plea bargain, or to prosecutorial decisions based on “an unjustifiable standard such as race, religion, or other arbitrary classification.” State v. Favre, 428 N.W.2d 828, 831 (Minn.App.1988) (quoting Wayte v. United States, 470 U.S. 598, 608 , 105 S.Ct. 1524, 1531 , 84 L.Ed.2d 547 (1985)).