Jada Sha'nel Monroe v. State of Indiana, 26S-CR-00208

Monroe was charged with murder, felony murder, and robbery resulting in serious bodily injury, and she pleaded guilty to all counts without a plea agreement. 1
At the plea and sentencing hearings, the parties agreed the felony-murder count should be merged or vacated to avoid double jeopardy, but Monroe also sought vacatur of the robbery conviction on the same ground. 2
The trial court entered judgments of conviction on murder and robbery, and the Court of Appeals affirmed, holding Monroe could not raise double jeopardy on direct appeal after a guilty plea. 3
The Indiana Supreme Court granted transfer and reviewed de novo whether a defendant may directly appeal a conviction after pleading guilty. 4
The majority reiterated Tumulty's rule that guilty-plea defendants generally must seek post-conviction relief, not direct appeal, to challenge convictions. 5
The dissent argued Monroe should be able to raise her double-jeopardy claim on direct appeal because she had no plea agreement, the record was sufficient, and the claim arose after the plea. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can Monroe directly appeal a double jeopardy claim after an open guilty plea? 7	State said Tumulty bars direct appeal after any guilty plea.	Monroe said no plea agreement means she may appeal an illegal conviction.	No; direct appeal unavailable absent a motion to withdraw the plea. 8
What procedure allows direct appellate review of a lesser-included conviction challenge? 9	State said Monroe used the wrong procedural route.	Monroe said the conviction should be vacated now.	Move to withdraw the guilty plea as to the lesser-included offense and appeal denial. 10
Did Monroe preserve a direct appeal by moving to withdraw her plea? 11	State said she did not preserve review.	Monroe argued the record and sentencing objections sufficed.	No; she never moved to withdraw the robbery plea, so post-conviction relief is required. 12

Tumulty v. State, 666 N.E.2d 394 (Ind. 1996) (guilty pleas generally cannot be challenged by direct appeal; post-conviction relief is the proper route 13)
Ortiz v. State, 278 N.E.3d 1151 (Ind. 2026) (de novo review applies to whether a guilty-plea conviction may be directly appealed 14)
Mayo v. State, 681 N.E.2d 689 (Ind. 1997) (bright-line guilty-plea rule supports efficiency and finality 15)
Hayes v. State, 906 N.E.2d 819 (Ind. 2009) (double jeopardy claims have been treated as barred by the guilty-plea appeal rule 16)
Mapp v. State, 770 N.E.2d 332 (Ind. 2002) (plea agreements waive double jeopardy challenges to agreed convictions 17)
Brightman v. State, 758 N.E.2d 41 (Ind. 2001) (denial of a motion to withdraw a guilty plea is directly appealable 18)
Crider v. State, 984 N.E.2d 618 (Ind. 2013) (defendant may expect sentencing to conform to law when no bargain fixes the sentence 19)
Wadle v. State, 151 N.E.3d 227 (Ind. 2020) (substantive double jeopardy analysis focuses on whether offenses are compressed into a single transaction 20)