Brightman v. State

Summary

The Supreme Court of Indiana affirmed the denial of Paul Brightman's motion to withdraw guilty pleas to two murder charges. The court held that the plea was entered freely and knowingly, rejected his ineffective-assistance claim, and concluded that the State was not judicially estopped from opposing withdrawal of the plea. The court also addressed Indiana Code § 35-35-1-4(b), governing withdrawal of guilty pleas before sentencing.

Holdings

1. The trial court did not abuse its discretion in denying Brightman's motion to withdraw his guilty plea because the plea-hearing record established that the plea was made freely and knowingly, and the evidence did not establish a manifest injustice or constitutionally deficient representation.
2. Brightman's guilty plea was voluntary and knowing because the plea colloquy showed that he understood the charges, potential sentences, rights waived, plea agreement, and factual basis, and that he was not coerced by threats or promises outside the agreement.
3. Brightman failed to prove ineffective assistance of counsel because he did not show that counsel's performance fell below an objective standard of reasonableness or that he suffered prejudice.
4. Judicial estoppel did not bar the State from opposing Brightman's motion to withdraw his guilty plea because the State's positions were not inconsistent and, in any event, the court had not acted on the State's prior motion to set aside the plea.

Questions Presented

1. Whether the trial court abused its discretion by denying Brightman's presentence motion to withdraw his guilty plea on the grounds that the plea was involuntary or that counsel was ineffective.
2. Whether the State should have been judicially estopped from opposing Brightman's motion to withdraw his guilty plea because the State had separately moved to set aside the plea based on an alleged breach of the plea agreement.

Disposition

affirmed