State of Montana v. Bryce Everett Peterson

Summary

The Montana Supreme Court reviews Bryce Everett Peterson’s motion to withdraw Alford pleas to multiple criminal charges. The court affirms the denial of plea withdrawal, concluding that the pleas were knowingly and voluntarily entered and that Peterson did not establish ineffective assistance of counsel. The court remands solely for determination of the amount of restitution for the victim’s future counseling expenses.

Holdings

1. The Court would not consider Peterson's claim that his trial or plea counsel was ineffective because that issue was not raised in the District Court in connection with the motion to withdraw the pleas.
2. Peterson failed to establish good cause to withdraw his Alford pleas because the record showed that he understood the direct consequences of the pleas and entered them knowingly, intelligently, and voluntarily.
3. Peterson did not demonstrate deficient performance because the record supported an inference that he acted purposely or knowingly to hinder law enforcement and prevent his arrest.
4. The restitution matter had to be remanded because the District Court was required to determine and specify the total amount of restitution for the victim's future counseling expenses.

Questions Presented

1. Whether the District Court properly denied Peterson's motion to withdraw his Alford pleas.
2. Whether Peterson's plea-withdrawal counsel was ineffective for failing to challenge the intimidation charge and for failing to present additional mental-health evidence.
3. Whether the restitution order had to specify the total amount of restitution for the victim's future counseling expenses.

Disposition

reversed_and_remanded