Withdrawal of Guilty Plea Generally.
Unless otherwise indicated, all indented material is copied directly from the court’s opinion.
Decisions of the Tennessee Supreme Court
Decisions of the Tennessee Court of Criminal Appeals
State v. Seidel, No. M2022-01169-CCA-R3-CD, p. 6 (Tenn. Ct. Crim. App. Sept. 15, 2023).
This court reviews a trial court’s decision regarding a motion to withdraw a guilty plea for an abuse of discretion. Phelps, 329 S.W.3d at 443 (citing State v. Crowe, 168 S.W.3d 731, 740 (Tenn. 2005)). An abuse of discretion occurs when a trial court “applies incorrect legal standards, reaches an illogical conclusion, bases its ruling on a clearly erroneous assessment of the proof, or applies reasoning that causes an injustice to the complaining party.” Id. (citing State v. Jordan, 325 S.W.3d 1, 38-40 (Tenn. 2010)). An appellate court will “also find an abuse of discretion when the trial court has failed to consider the relevant factors provided by higher courts as guidance for determining an issue.” Id. (citing State v. Lewis, 235 S.W.3d 136, 141 (Tenn. 2007)).
State of Tennessee v. Brooks, No. E2020-01563-CCA-R3-CD (Tenn. Ct. Crim. App. Mar. 3, 2022).
A trial court’s decision regarding a defendant’s motion to withdraw a plea is reviewed for an abuse of discretion. Phelps, 329 S.W.3d at 443 (citing State v. Crowe, 168 S.W.3d 731, 740 (Tenn. 2005)). “An abuse of discretion exists if the record lacks substantial evidence to support the trial court’s conclusion.” Crowe, 168 S.W.3d at 740 (citing Goosby v. State, 917 S.W.2d 700, 705 (Tenn. Crim. App. 1995)). A trial court also abuses its discretion “when it applies incorrect legal standards, reaches an illogical conclusion, bases its ruling on a clearly erroneous assessment of the proof, . . . applies reasoning that causes an injustice to the complaining party[, or] . . . fail[s] to consider the relevant factors provided by higher courts as guidance for determining an issue.” Phelps, 329 S.W.3d at 443 (internal citations omitted).
State of Tennessee v. Jones, No. M2021-00087-CCA-R3-CD (Tenn. Ct. Crim. App. Feb. 28, 2022).
This Court reviews a trial court’s determination regarding a motion to withdraw a guilty plea for an abuse of discretion. State v. Phelps, 329 S.W.3d 436, 443 (Tenn. 2010). An abuse of discretion occurs when a trial court “applies incorrect legal standards, reaches an illogical conclusion, bases its ruling on a clearly erroneous assessment of the proof, . . . applies reasoning that causes an injustice to the complaining party[, or] . . . fail[s] to consider the relevant factors provided by higher courts as guidance for determining an issue.” Id. (internal citations omitted).
State of Tennessee v. Norton, No. E2020-01652-CCA-R3-CD (Tenn. Ct. Crim. App. Jan. 25, 2022).
The Supreme Court has concluded that a guilty plea must represent a “voluntary and intelligent choice among the alternative courses of action open to the defendant.” North Carolina v. Alford, 400 U.S. 25, 31 (1970). A trial court must examine in detail “the matter with the accused to make sure he has a full understanding of what the plea connotes and of its consequence.” Boykin v. Alabama, 395 U.S. 238, 243-44 (1969); see Blankenship v. State, 858 S.W.2d 897, 904 (Tenn. 1993). Appellate courts examine the totality of circumstances when determining whether a guilty plea was voluntarily and knowingly entered. State v. Turner, 919 S.W.2d 346, 353 (Tenn. Crim. App. 1995). A guilty plea is not voluntary if it is the result of “[i]gnorance, incomprehension, coercion, terror, inducements, [or] subtle or blatant threats.” Boykin, 395 U.S. at 242-43; see Blankenship, 858 S.W.2d at 904. A petitioner’s representations and statements under oath that his guilty plea is knowing and voluntary create “a formidable barrier in any subsequent collateral proceedings [because] [s]olemn declarations . . . carry a strong presumption of verity.” Blackledge v. Allison, 431 U.S. 63, 74 (1977).
State of Tennessee v. Abdulkarim, No. M2020-00502-CCA-R3-CD (Tenn. Ct. Crim. App. Jan. 13, 2022).
A trial court’s determination regarding a motion to withdraw a guilty plea is reviewed for an abuse of discretion. [State v.] Phelps, 329 S.W.3d [436,]443 [(Tenn. 2010)]. An abuse of discretion occurs when a trial court “applies incorrect legal standards, reaches an illogical conclusion, bases its ruling on a clearly erroneous assessment of the proof, . . . applies reasoning that causes an injustice to the complaining party . . . [and] fail[s] to consider the relevant factors provided by higher courts as guidance for determining an issue.” Id.).
