State v. Locke

Summary

The Montana Supreme Court affirmed the denial of James Curtis Locke’s motion to withdraw his Alford plea to felony robbery. The Court held that Locke voluntarily, knowingly, and intelligently entered the plea and that the record supported its acceptance under Montana law. Justice James C. Nelson dissented, concluding that the district court failed to establish the required strong factual basis for the Alford plea.

Holdings

1. Locke voluntarily, knowingly, and intelligently entered his Alford plea and failed to establish good cause to withdraw it.
2. Under § 46-12-212(2), MCA, a court may accept an Alford plea from a defendant who does not admit the offense when the defendant considers the plea in the defendant's best interest and the record contains a factual basis, including strong evidence of guilt, supporting the charge.

Questions Presented

1. Whether the district court properly denied Locke's motion to withdraw his Alford plea.
2. Whether Locke voluntarily, knowingly, and intelligently entered the Alford plea.
3. Whether the district court's reliance on the information and affidavit, together with Locke's understanding of the plea and the evidence, provided a sufficient basis to accept the Alford plea under Montana law.

Disposition

affirmed