This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant was indicted on a single count of breaking and entering. He entered a plea of no contest. Subsequently, defense counsel discovered evidence suggesting that the Defendant was mentally retarded and incapable of entering the plea knowingly, intelligently, or voluntarily. The Defendant had a history of intellectual disability, including a prior determination of incompetence in a separate case, and evaluations indicating a low IQ and limited understanding of legal proceedings (paras 1, 3, 5, 7, 9, 11, 13, 15).
Procedural History
- District Court, April 7, 2006: The Defendant entered a plea of no contest and received a conditional discharge with probation and mental health court requirements (para 5).
- District Court, June 2006: Defense counsel filed a motion to reconsider the sentence, citing new evidence of the Defendant’s incompetence (para 7).
- District Court, December 2006: In a separate case, the Defendant was found incompetent to stand trial and the charges were dismissed (para 9).
- District Court, August 2006: A hearing was held on the Defendant’s motion to withdraw the plea and dismiss for competency, which was denied (paras 9, 11).
Parties' Submissions
- Appellant (Defendant): Argued that he was not competent to enter the plea knowingly or voluntarily due to his intellectual disability and that the district court abused its discretion in denying the motion to withdraw the plea (paras 1, 13, 15).
- Appellee (State): Contended that the Defendant failed to meet the burden of proving incompetence and that the plea was validly entered based on the plea colloquy and defense counsel’s assurances at the time (paras 5, 7, 15).
Legal Issues
- Whether the Defendant was competent to enter a plea of no contest.
- Whether the district court abused its discretion in denying the motion to withdraw the plea and dismiss for competency.
Disposition
- The Court of Appeals reversed the district court’s denial of the motion to withdraw the plea and remanded the case for further proceedings (para 15).
Reasons
Per Robles J. (Wechsler and Garcia JJ. concurring):
The Court found that the uncontradicted evidence, including expert testimony, established that the Defendant lacked the capacity to understand the nature and consequences of the proceedings or to assist in his defense. Dr. Harrington’s testimony demonstrated that the Defendant’s intellectual disability rendered him unable to comprehend the plea process, despite his affirmative responses during the plea colloquy. The district court erred in relying on the transcript of the plea hearing and in conflating the standards for mental illness and mental retardation. The Court concluded that the district court’s denial of the motion to withdraw the plea constituted an abuse of discretion and a manifest injustice (paras 11-15).