State v. Miles

Summary

The Kansas Supreme Court affirmed the denial of Tracie Miles' postsentencing motion to withdraw no-contest pleas to premeditated first-degree murder, aggravated robbery, and forgery. The court held that any prejudice from counsel's alleged misinformation about the charges and possible penalties was cured by the trial judge's thorough plea colloquy. Because Miles failed to establish manifest injustice, the district court did not abuse its discretion.

Holdings

1. A criminal defendant is not entitled to withdraw a no-contest plea after sentencing for manifest injustice when the alleged deficiency in counsel's performance was fully corrected by the court before the plea was entered.
2. The denial of a postsentencing motion to withdraw a plea is reviewed for abuse of discretion, and reversal is warranted when the district court acts unreasonably, applies an erroneous legal conclusion, or relies on a factual finding unsupported by substantial competent evidence.

Questions Presented

1. Whether Miles established manifest injustice warranting withdrawal of her no-contest pleas after sentencing.
2. Whether alleged misinformation or inadequate advice from counsel required plea withdrawal when the district court fully corrected or clarified the information before accepting the pleas.
3. Whether the district court abused its discretion in denying the postsentencing motion to withdraw pleas.

Disposition

affirmed