In re Anthony Bridger, 176 A.3d 489

Anthony Bridger pled guilty in 2010 to 16 counts of burglary in Rutland County after earlier related pleas in other counties; affidavits in the record recited his detailed confession and victims' complaints.
At the Rutland change-of-plea hearing the court explained elements and penalties, asked Bridger whether he understood, and asked if the troopers' affidavits provided a factual basis; Bridger answered "yes."
Bridger later filed a petition for post-conviction relief (PCR) in 2015, arguing the Rule 11(f) colloquy lacked an adequate factual-basis inquiry because he never personally admitted specific facts from the affidavits on the record.
The PCR court granted summary judgment for the State, relying on precedent permitting substantial compliance or stipulation to a factual basis (citing Cleary and Morrissette).
The Vermont Supreme Court reversed, holding Rule 11(f) requires an on-the-record showing that the defendant admits facts sufficient to satisfy each element of the charged offenses (not merely a generic assent to affidavits).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the plea colloquy satisfied V.R.Cr.P. 11(f)'s factual-basis requirement	Bridger: his generic "yes" to affidavits did not constitute an admission of facts establishing each element	State: the court may rely on affidavits and a defendant's agreement that those affidavits provide a factual basis; substantial compliance suffices	Court held Rule 11(f) was not satisfied — defendant must personally admit facts that relate to each element; mere generic assent to affidavits is inadequate
Whether "substantial compliance" is an acceptable standard under Rule 11(f) in collateral attack	Bridger: argued strict compliance required (citing Stocks)	State: relied on cases using substantial-compliance language (Morrissette, Cleary)	Court held "substantial compliance" has no place in Rule 11(f) collateral challenges and overruled conflicting precedent to that extent
Whether a court may rely on affidavits alone without defendant admissions	Bridger: affidavits alone are insufficient unless defendant admits the same facts on the record (Yates)	State: affidavits + defendant's assent to their sufficiency is enough	Court held affidavits may be sources of facts but defendant must admit those facts on the record for Rule 11(f) purposes
Remedy where Rule 11(f) not satisfied on the record	Bridger: sought to withdraw plea	State: opposed	Court reversed PCR denial and remanded to permit withdrawal of plea (entry of judgment allowing withdrawal)

In re Dunham, 479 A.2d 144 (Vt. 1984) (establishes that the record must affirmatively show facts satisfying each element and links factual-basis inquiry to voluntariness)
State v. Yates, 726 A.2d 483 (Vt. 1999) (affidavits can be a source of facts, but defendant must admit those facts on the record)
In re Stocks, 94 A.3d 1143 (Vt. 2014) (requires evidence of a judge's specific inquiry into factual basis; defendant must affirm accuracy, not merely understanding)
In re Manosh, 108 A.3d 212 (Vt. 2014) (court must personally address defendant on Rule 11 matters; limited waiver exceptions under Rule 43)
State v. Cleary, 824 A.2d 509 (Vt. 2003) (earlier case applying "substantial compliance," overruled to extent inconsistent with Dunham/Manosh)
McCarthy v. United States, 394 U.S. 459 (U.S. 1969) (federal precedent emphasizing that a plea cannot be truly voluntary unless defendant understands law in relation to facts)
Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (requires canvassing defendant on the record to ensure voluntariness of plea)