Jada Sha'nel Monroe v. State of Indiana

Summary

The Indiana Supreme Court holds that a defendant who pleads guilty generally may not challenge the resulting convictions on direct appeal, including on double-jeopardy grounds. The court explains that a defendant who did not agree through a plea agreement to a lesser-included conviction may instead move to withdraw the guilty plea as to that conviction and seek its vacation, then directly appeal the denial of that motion. Because Jada Monroe did not pursue that procedure, the court summarily affirmed the Court of Appeals’ decision.

Holdings

1. A defendant who pleads guilty generally may not challenge the validity of the resulting convictions through a direct appeal; the claim must ordinarily be pursued through post-conviction relief. The court declined to create an exception for defendants who plead guilty without a plea agreement.
2. When a trial court enters judgment on a lesser-included offense after a guilty plea, and the defendant did not agree through a plea agreement that the conviction would be entered or sentenced, the defendant should move to withdraw the guilty plea as to only the lesser-included offense and ask the trial court to vacate only that conviction.
3. An appellate court reviews denial of a motion to withdraw a guilty plea for abuse of discretion. If the challenged conviction violates double jeopardy, denial of the motion constitutes an abuse of discretion; if no violation exists, there is no abuse of discretion.

Questions Presented

1. Whether a defendant who pleads guilty without a plea agreement may directly appeal a conviction on double-jeopardy grounds.
2. Whether a defendant may obtain direct appellate review of an allegedly improper lesser-included conviction by moving to withdraw the guilty plea as to that offense and appealing the denial of that motion.
3. Whether Monroe's direct appeal was available when she did not move to withdraw her guilty plea as to the robbery conviction.

Disposition

affirmed