AI Generated Opinion Summaries

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 entered a no contest plea in a criminal case. Subsequently, the Defendant sought to withdraw the plea, arguing that it was not entered knowingly and voluntarily. The case centers on whether the plea withdrawal should be permitted.

Procedural History

• District Court, Doña Ana County: The Defendant's motion to withdraw the no contest plea was denied. (headnotes)

Parties' Submissions

• Defendant-Appellant: Argued that the motion to withdraw the plea should be reviewed under the "fair and just reason" standard, as suggested in the Committee Comment to Rule 5-304 NMRA. The Defendant contended that the plea was not entered knowingly and voluntarily.
• Plaintiff-Appellee: Argued that the district court correctly applied the "manifest injustice" standard, as established in State v. Hunter, 2006-NMSC-043, and that the plea was knowingly and voluntarily entered.

Legal Issues

• Whether the district court abused its discretion in denying the Defendant's motion to withdraw the no contest plea.
• Whether the "fair and just reason" standard should apply instead of the "manifest injustice" standard in reviewing the motion to withdraw the plea.

Disposition

• The Court of Appeals affirmed the district court's denial of the Defendant's motion to withdraw the no contest plea.

Reasons

Per Fry CJ. (Bustamante and Garcia JJ. concurring):

The Court of Appeals reviewed the district court's decision under the "abuse of discretion" standard, as established in State v. Hunter, 2006-NMSC-043. An abuse of discretion occurs when the district court acts unfairly, arbitrarily, or commits manifest error. Manifest error is present when the undisputed facts show that the plea was not entered knowingly and voluntarily.

The Court found that the undisputed facts indicated the Defendant's plea was knowingly and voluntarily entered. The Defendant's argument for applying the "fair and just reason" standard was rejected, as the Supreme Court in Hunter had already established the "manifest injustice" standard. The Court of Appeals declined to overrule Supreme Court precedent, citing Alexander v. Delgado, 84 N.M. 717, 718, 507 P.2d 778, 779 (1973).

For these reasons, the Court affirmed the district court's decision.