Jackson v. State
2012 WY 56
| Wyo. | 2012Background
- Jackson pled guilty to one count of third degree sexual assault under a plea agreement that deferred judgment of guilt and placed him on five years of probation under § 7-13-301.
- Six months after sentencing, the State moved to revoke probation; proceedings on the revocation were delayed, and a year later Jackson moved to withdraw his guilty plea based on a victim recantation identifying another perpetrator.
- The district court denied the motion to withdraw and revoked probation, sentencing Jackson to four to five years with a recommendation for boot camp.
- Jackson argued the district court abused its discretion by denying withdrawal of the plea.
- The Supreme Court of Wyoming affirmed, holding no abuse of discretion or due process violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of the motion to withdraw guilty plea was an abuse of discretion | Jackson contends denial was an abuse of discretion | State argues denial was within the court's discretion | No abuse; district court reasonably denied the motion |
| Whether Rule 11 requirements at arraignment/plea were satisfied | Jackson argues Rule 11 deficiencies affected voluntariness | State contends Rule 11 compliance was adequate | Rule 11 compliance not violated; plea voluntary to a sufficient degree |
| Whether the evidence was newly discovered to warrant withdrawal under Rule 32(d) | Jackson asserts victim's recantation constitutes newly discovered evidence | State asserts evidence was known via PSI and not new | Evidence not newly discovered; district court properly denied withdrawal |
Key Cases Cited
- Murphy v. State, 592 P.2d 1159 (Wyo. 1979) (Rule 11 analysis in withdrawal context; not presented in district court but reviewed on appeal)
- Bonney v. State, 248 P.3d 637 (Wyo. 2011) (Acceptance of guilty plea with minimal factual basis may be upheld under appropriate conditions)
- Wilson v. State, 68 P.3d 1181 (Wyo. 2003) (Adequacy of factual basis when defendant does not testify and relies on State’s recitation)
- Rude v. State, 851 P.2d 15 (Wyo. 1993) (Advocates better record to assess competence and understanding in plea process)
- Jones v. State, 203 P.3d 1091 (Wyo. 2009) (Rule 11(f) factual basis standard for guilty plea)
- Maes v. State, 114 P.3d 708 (Wyo. 2005) (Factual basis sufficiency; reliance on State's description of evidence permissible at times)
- Garza v. State, 231 P.3d 884 (Wyo. 2010) (Recanted testimony weighed with skepticism; district court credibility determination deferred to)