Mason v. People

Summary

The Colorado Supreme Court held that a defendant who has pleaded guilty and been sentenced may, in appropriate circumstances, seek to withdraw the plea based on newly discovered evidence. Applying the standard articulated in People v. Schneider, the court concluded that Mason failed to show that the newly discovered confession would probably result in an acquittal or otherwise justify vacating his convictions. The court affirmed the court of appeals' decision upholding denial of postconviction relief.

Holdings

1. A defendant who has entered and been sentenced on a valid guilty plea may, under certain circumstances, seek to withdraw the plea under Criminal Procedure Rule 35(c) to avoid manifest injustice.
2. The defendant must present evidence from which the trial court may reasonably conclude that: (1) the evidence was discovered after the plea and could not earlier have been discovered through reasonable diligence; (2) the charges filed or the charges to which the defendant pleaded were actually false or unfounded; and (3) the evidence would probably produce an acquittal at trial.
3. Mason was not entitled to withdrawal of his guilty plea or a new trial because he failed to show that the newly discovered evidence would probably produce an acquittal.

Questions Presented

1. Whether a defendant who has entered a valid guilty plea and been sentenced may seek postconviction relief under Criminal Procedure Rule 35(c) based on newly discovered evidence.
2. Whether the newly discovered evidence required reversal or remand under the standard governing withdrawal of a guilty plea after sentencing.
3. Whether the trial court's findings established that the newly discovered evidence would probably produce an acquittal at trial.

Disposition

affirmed