Arriaga v. State, 469 P.3d 914

In 2010 Benjamin Arriaga shot and killed Benacio Herrera; he told police the shooting was accidental or in self-defense after an altercation over an alleged affair.
State charged Arriaga with first-degree murder, unlawful possession/use of a firearm, and obstruction; Arriaga pled guilty to first-degree murder in exchange for dismissal of the other counts and was sentenced to 15 years-to-life.
The written Plea Affidavit was bilingual (English/Spanish) and listed the elements and a brief factual basis; at the plea colloquy Arriaga (through an interpreter) made statements suggesting he acted in self-defense while also acknowledging he knew pulling the trigger could cause death.
On PCRA review Arriaga argued (1) his plea was unknowing/unvoluntary because he did not understand that absence of imperfect self-defense is an element the State had to negate, and (2) trial counsel was ineffective for failing to obtain an interpreter for client meetings.
The post-conviction court granted the State summary judgment; the court of appeals affirmed. The Utah Supreme Court granted certiorari and affirmed the court of appeals: it held a genuine factual dispute existed on whether the plea was knowing, but Arriaga failed to show prejudice; it also held Arriaga failed to show counsel’s performance was objectively deficient.

Issue	Arriaga's Argument	State's Argument	Held
Whether Arriaga’s guilty plea was knowing and voluntary because he did not understand that absence of imperfect self-defense is an element of murder	Arriaga: plea was unknowing because he misunderstood imperfect self-defense’s effect; plea colloquy and affidavit show confusion	State: colloquy, affidavit, and counsel’s assurances show Arriaga understood plea; no relief	Court: Genuine factual dispute exists whether Arriaga understood the element, so the post-conviction court erred on that narrow point; but Arriaga failed to prove prejudice, so relief denied
Whether trial counsel was constitutionally ineffective by not obtaining an interpreter for attorney-client meetings	Arriaga: language barrier prevented adequate advice and understanding of plea; counsel’s failure was deficient	State: Arriaga affirmatively told the court he understood counsel, Plea Affidavit bilingual, no evidence he requested an interpreter—no deficient performance shown	Court: Arriaga produced no evidence counsel’s performance fell below objective standard; no genuine factual dispute; claim fails

State v. Alexander, 279 P.3d 371 (Utah 2012) (standard for knowing and voluntary plea; look to understanding of law in relation to facts)
State v. Low, 192 P.3d 867 (Utah 2008) (imperfect self-defense is an affirmative defense such that the State must negate its existence when defendant offers evidence)
Lee v. United States, 137 S. Ct. 1958 (2017) (special-circumstances rule: in limited situations a plea decision may turn on considerations other than trial success, requiring substantial contemporaneous evidence)
Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for plea cases: reasonable probability that but for error defendant would have gone to trial)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
Blackledge v. Allison, 431 U.S. 63 (1977) (solemn in-court plea statements carry strong presumption of verity)