Arriaga v. State, 436 P.3d 222

Benjamin Arriaga admitted shooting and killing a man who was having an affair with his wife; the victim was shot multiple times. Arriaga confessed to police; a suppression motion for that confession was denied.
State charged murder (first-degree) and two felony weapons/obstruction counts; plea deal: Arriaga plead guilty to murder and the other charges were dismissed.
Plea affidavit was provided in English and Spanish and an interpreter was present at the plea hearing; Arriaga acknowledged he understood his rights, the affidavit, and that he waived the right to withdraw and to a jury trial.
During the plea colloquy Arriaga made statements suggesting self-defense/imperfect self-defense; the court questioned him and he acknowledged he knew pulling the trigger could cause death.
Postconviction petition alleged the plea was unknowing/involuntary and counsel was ineffective because trial counsel did not use an interpreter during out-of-court consultations; district court granted State summary judgment and denied relief.
Utah Court of Appeals affirms, holding the plea was knowing and voluntary and counsel’s failure to secure an interpreter was not shown to be deficient or prejudicial.

Issue	Arriaga's Argument	State's Argument	Held
Whether the guilty plea was knowing and voluntary	Arriaga says he did not understand the elements of murder or imperfect self-defense (language barrier, limited education) so plea was unknowing	Plea affidavit (English/Spanish), interpreter at colloquy, and Arriaga’s own statements show he understood rights and elements	Court held plea was knowing and voluntary; colloquy and affidavit cured any misunderstanding
Whether counsel was ineffective for not using an interpreter in out-of-court meetings	Counsel’s failure to secure an interpreter was unreasonable and prevented Arriaga from understanding defenses, so prejudice exists	Even if arguable deficiency, Arriaga cannot show prejudice: given confession, facts (multiple shots, shots to back/head), it was not reasonable to reject plea and go to trial	Court held Arriaga failed to prove deficient performance and, critically, failed to show a reasonable probability he would have rejected the plea and insisted on trial

Bradshaw v. Stumpf, 545 U.S. 175 (guilty plea must be voluntary, knowing, and intelligent)
Blackledge v. Allison, 431 U.S. 63 (solemn in-court plea statements carry a strong presumption of verity)
Strickland v. Washington, 466 U.S. 668 (standard for ineffective assistance of counsel)
State v. Low, 192 P.3d 867 (absence of affirmative defenses is an element of murder; imperfect self-defense explained)
United States v. Weeks, 653 F.3d 1188 (statements at plea colloquy are conclusive absent a believable reason to depart)
State v. Maguire, 830 P.2d 216 (court must clarify omissions/ambiguities in plea affidavit during plea hearing)