Joe Anthony Robert Sandoval v. the State of Texas, 03-19-00527-CR

Appellant Joe Sandoval entered an open guilty plea to first-degree murder with the right to appeal; he signed written admonishments, waivers, and a stipulation of evidence and represented he was mentally competent and pleading voluntarily.
At the plea hearing the court admonished Sandoval, questioned him about a prior 40-year offer, observed brief hesitation, conferred with counsel, and accepted the plea after finding it freely and voluntarily given.
Sandoval later filed a motion to withdraw his plea (after the case was taken under advisement), supported by counsel’s affidavit and a May 9 letter from Sandoval claiming confusion about the plea terms and a desire to go to trial.
Records included a 2004 TYC intake showing a full-scale IQ of 71 and below-average memory, and a June 2018 psychologist’s evaluation finding poor recent memory but competency to stand trial and ability to engage in reasoned legal choices while medicated.
The trial court denied the motion to withdraw, sentenced Sandoval to 37 years’ confinement, and Sandoval appealed arguing his plea was not knowing and voluntary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying Sandoval’s post-advisement request to withdraw his guilty plea because the plea was not knowing and voluntary	Sandoval: mental illness, low IQ, memory deficits, confusion about plea terms, hesitation, and counsel’s concerns show plea was not knowingly or voluntarily made	State/Trial court: proper admonishments, Sandoval’s written admissions and responses at plea hearing, and 2018 psychologist’s finding of competency support that plea was knowing and voluntary	Court affirmed: no abuse of discretion; entire record supports that plea was knowingly and voluntarily made

Jackson v. State, 590 S.W.2d 514 (Tex. Crim. App. 1979) (withdrawal of plea is a right before judgment; discretionary after case is taken under advisement)
Ex parte Mable, 443 S.W.3d 129 (Tex. Crim. App. 2014) (guilty plea must be knowing and voluntary; defendant must have sufficient awareness of relevant circumstances)
Briggs v. State, 560 S.W.3d 176 (Tex. Crim. App. 2018) (defendant who attests plea was knowing bears burden to show involuntariness on appeal)
Gonzales v. State, 544 S.W.3d 363 (Tex. Crim. App. 2018) (abuse-of-discretion standard governing trial-court rulings)
Martinez v. State, 981 S.W.2d 195 (Tex. Crim. App. 1998) (proper admonishment creates prima facie showing that plea was knowing and voluntary)
Brady v. United States, 397 U.S. 742 (1970) (waivers in plea context must be voluntary, knowing, and intelligent)
Parke v. Raley, 506 U.S. 20 (1992) (plea voluntariness measured as an intelligent choice among alternatives)
Saldana v. State, 150 S.W.3d 486 (Tex. App.—Austin 2004) (discussing trial-court discretion to deny post-advisement plea withdrawals)