G.E.G. v. State

Summary

The Alabama Supreme Court considered whether the Court of Criminal Appeals erred in reversing the denial of G.E.G.’s motion to withdraw guilty pleas to drug-related charges. The court held that the rule requiring corroboration of an extrajudicial confession does not apply to a guilty-plea conviction because a voluntary guilty plea is a judicial confession and conclusively establishes guilt. The court reversed and remanded.

Holdings

1. The rule requiring independent corroboration of a confession to establish the corpus delicti does not apply to a conviction entered on a voluntary and knowing guilty plea. A guilty plea is a judicial confession and conclusively establishes the defendant's guilt as to the facts sufficiently charged.
2. Rule 14.4(b), Ala. R. Crim. P., requires only a factual basis sufficient to satisfy the trial court that the defendant knows what he or she is pleading guilty to and that the admitted acts constitute the charged offense; it does not require evidence independently establishing guilt beyond a reasonable doubt.
3. The record supplied an adequate factual basis for G.E.G.'s guilty pleas to second-degree possession of marijuana and possession of drug paraphernalia, and the Court of Criminal Appeals erred by reversing those convictions based on the absence of independent corroboration.

Questions Presented

1. Whether the rule requiring corroboration of an extrajudicial confession before a defendant may be convicted applies to a conviction based on a voluntary guilty plea.
2. Whether the factual basis required by Rule 14.4(b), Ala. R. Crim. P., was sufficient when the guilty-plea record included the indictment, the prosecutor's factual assertions, and the defendant's voluntary plea.
3. Whether the Court of Criminal Appeals erred by reversing the denial of G.E.G.'s motion to withdraw his guilty pleas to the drug-related charges.

Disposition

reversed_and_remanded