Eaton v. State
793 N.W.2d 790
N.D.2011Background
- Eaton pleaded guilty on August 3, 2004 to possession of a controlled substance with intent to deliver and to possession of drug paraphernalia.
- State provided a factual basis including eighty grams of methamphetamine found at Eaton’s residence, pay-owe sheets, scales, shipping documents, plane tickets, and miscellaneous paraphernalia.
- District court accepted the guilty pleas after determining the factual basis was sufficient and sentenced Eaton to five years on each count, concurrent.
- Eaton filed post-conviction relief petitions in 2009–2010, arguing the plea lacked a sufficient factual basis.
- The district court denied post-conviction relief by summary disposition; Eaton appealed challenging the sufficiency of the factual basis to support the plea.
- This appeal reviews a summary denial in a post-conviction proceeding, with questions of law about the sufficiency of the factual basis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the factual basis sufficient for the plea? | Eaton argues the basis shows only constructive possession and lacks intent-to-deliver evidence. | The State contends the quantity and accompanying items support intent to deliver and possession. | Yes; the factual basis, together with the surrounding evidence, supports intent to deliver and possession. |
| May the court infer intent to deliver from the record? | Eaton contends the court cannot infer intent since Eaton contested intent at plea. | The State argues the quantity and items permit an inference of intent to deliver; the court may rely on these facts. | Yes; the court may infer intent to deliver from the amount and corroborating items. |
| Can a defendant withdraw a guilty plea on post-conviction relief? | Eaton seeks withdrawal; argues the plea should be vacated due to insufficient basis. | State contends withdrawal requires manifest injustice and the court has discretion. | Not on the merits of withdrawal here; court reviews manifest-injustice standard, but appeal addresses sufficiency of the basis. |
| What is the appropriate standard of review for a summary denial in post-conviction relief? | Review of the district court’s legal conclusions is de novo. | The court treats issues as questions of law, with full review of legal basis for the plea. | Legal questions are fully reviewable; summary denial affirmed on the basis of a sufficient factual basis. |
Key Cases Cited
- State v. Fickert, 780 N.W.2d 670 (N.D. 2010) (establishing factual basis for a guilty plea and role of the court in evaluating it)
- Bates, 726 N.W.2d 595 (N.D. 2007) (use of prosecutor’s offer of proof to establish a factual basis)
- Froistad, 641 N.W.2d 86 (N.D. 2002) (preservation and evaluation of factual basis in plea proceedings)
- Hamann, 262 N.W.2d 495 (N.D. 1978) (Rule 11 factual basis requirement and evaluation methods)
- DeCoteau, 325 N.W.2d 187 (N.D. 1982) (supplementing factual basis with additional record information)
- Oie, 704 N.W.2d 573 (N.D. 2005) (open court inquiry and record information to support factual basis)
- Morris, 331 N.W.2d 48 (N.D. 1983) (intent element and sufficiency of evidence for possession with intent to deliver)
- Delvo v. State, 782 N.W.2d 72 (N.D. 2010) (post-conviction relief review framework)
- Patten v. State, 745 N.W.2d 626 (N.D. 2008) (treatment of post-conviction relief as under N.D.R.Crim.P. 11(d))