State v. Beckley

Summary

The Supreme Court of South Dakota affirmed Joshua Steven Beckley's guilty plea to possession of methamphetamine, holding that the trial court's failure to advise him of the right to compel witnesses at the plea hearing did not render the plea involuntary or unintelligent. The court reversed and remanded for resentencing because the trial court abused its discretion by denying a continuance to obtain a psychological evaluation relevant to mitigation, particularly in light of the court's reliance on Beckley's sexual proclivities in imposing sentence.

Holdings

1. Failure to advise a defendant of the right to compulsory process does not automatically invalidate a guilty plea when the record, considered under the totality of the circumstances, establishes that the plea was knowing and voluntary. Because Beckley had counsel, had been advised of the right twice previously, had entered a plea agreement, and had actually subpoenaed a witness for sentencing, his plea was knowing and voluntary.
2. The circuit court abused its discretion by denying Beckley's continuance request without properly considering the relevant continuance factors, where the requested psychological evaluation concerned the principal aggravating subject in the court's sentencing decision and could have supplied relevant mitigating evidence.

Questions Presented

1. Whether Beckley was entitled to withdraw his guilty plea because the court did not advise him at the change-of-plea hearing of his right to compel witnesses.
2. Whether the circuit court abused its discretion and violated Beckley's statutory right to present mitigating information by denying a continuance to obtain a psychological evaluation before sentencing.

Disposition

reversed_and_remanded