Jeremy Shane Zimmerman v. State of Minnesota, A16-1261

Zimmerman, required to register as a predatory offender, told St. Paul police he was homeless and living in his car and registered as homeless.
Officer Cherry told Shakopee police Zimmerman might be staying at an unregistered Shakopee address; two women (including his mother) told investigators he stayed overnight at their Shakopee residences and received mail there.
Zimmerman was charged with two counts of violating predatory-offender-registration requirements for conduct between Oct. 20 and Dec. 17, 2015.
After jury selection but before trial, Zimmerman pled guilty to knowingly violating the registration requirement or intentionally providing false information; he was sentenced to 39 months and a ten-year conditional-release term.
Post-sentencing, Zimmerman moved to withdraw his guilty plea alleging the plea was invalid (inaccurate) because the factual colloquy did not establish the required mens rea; the district court denied the motion.
The court of appeals reversed and remanded, holding the plea colloquy failed to establish that Zimmerman knowingly or intentionally violated the registration statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Zimmerman may withdraw his guilty plea for manifest injustice	Zimmerman: plea inaccurate because factual basis did not establish requisite mens rea (knowingly/intentionally)	State: record shows he had a secondary Shakopee address and therefore plea was accurate	Reversed: plea inaccurate—colloquy did not establish knowledge/intent to violate registration requirement

State v. Raleigh, 778 N.W.2d 90 (Minn. 2010) (describing manifest-injustice standard and accuracy/voluntariness/intelligence elements of a valid plea)
Munger v. State, 749 N.W.2d 335 (Minn. 2008) (explaining requirement for an adequate factual basis to support a plea)
State v. Her, 862 N.W.2d 692 (Minn. 2015) (addressing jury findings for facts that increase conditional-release terms)