State of Tennessee v. Terry Phelps

Summary

The Supreme Court of Tennessee held that the trial court applied the wrong legal analysis in denying Terry Phelps's presentence motion to withdraw his guilty plea. The court adopted a nonexclusive, multifactor approach for determining whether a defendant has shown a fair and just reason under Tennessee Rule of Criminal Procedure 32(f). It reversed the judgments of the trial court and Court of Criminal Appeals, granted the motion to withdraw the plea, and remanded for further proceedings.

Holdings

1. Under Tennessee Rule of Criminal Procedure 32(f)(1), a presentence motion to withdraw a guilty plea should be evaluated under a nonexclusive, multi-factor analysis of whether the defendant has shown any fair and just reason for withdrawal.
2. The trial court abused its discretion, and the Court of Criminal Appeals compounded the error, by denying the motion on the ground that Phelps had merely experienced a change of heart without applying the relevant multi-factor analysis.
3. Phelps established a fair and just reason for withdrawing his guilty plea before sentencing.
4. Phelps's challenge to his sentence was moot because he had served the entire sentence.

Questions Presented

1. What standard and factors govern a defendant's presentence motion to withdraw a guilty plea under Tennessee Rule of Criminal Procedure 32(f)(1)?
2. Did the trial court abuse its discretion by denying Phelps's motion without applying the proper nonexclusive multi-factor fair-and-just-reason analysis?
3. Did Phelps establish a fair and just reason for withdrawing his guilty plea?
4. Was Phelps's challenge to his completed sentence moot?

Disposition

reversed_and_remanded