Maes v. State

Summary

The Supreme Court of Wyoming held that Eli Maes's guilty pleas were voluntary despite his motivation to protect his wife from prosecution. The court also held that sufficient factual bases supported his guilty pleas to two counts of attempted voluntary manslaughter, including his Alford plea, and affirmed the convictions.

Holdings

1. A guilty plea is not involuntary merely because the defendant was motivated in part by a desire to protect a family member, where the record shows compliance with W.R.Cr.P. 11(d), awareness of the plea's direct consequences, and no threats, misrepresentation, improper promises, or manufactured charges against the family member.
2. A sufficient factual basis existed for Maes's guilty pleas to attempted voluntary manslaughter because the court could rely on the State's proffered witness and circumstantial evidence, together with Maes's admissions that he possessed and pointed the gun, even though he denied intending to kill or hurt anyone.

Questions Presented

1. Whether Maes's guilty pleas were voluntary when the plea agreement included benefits for his wife and protection from potential federal charges.
2. Whether a sufficient factual basis existed for Maes's guilty pleas to two counts of attempted voluntary manslaughter despite his statements that he did not intend to kill or hurt anyone.

Disposition

affirmed