Nykie C. Edwards v. State of Indiana (mem. dec.), 79A04-1701-CR-42

Edwards, age 22, had sexual intercourse with his girlfriend’s 13-year-old sister; State charged him with three counts of felony child molesting.
Edwards signed a written plea agreement to plead guilty to one count; two counts were to be dismissed and executed sentence capped at 30 years.
At the April 26, 2016 plea hearing Edwards acknowledged reviewing and signing the plea, stated his plea was voluntary, and admitted guilt; court accepted the plea and entered judgment.
On June 30, 2016 Edwards moved to withdraw his guilty plea; he contended he had not had time to analyze text and Facebook messages before pleading.
The trial court held a hearing, found the plea was freely and voluntarily given, that Edwards admitted the crime, and that he failed to present specific facts showing manifest injustice; the court denied withdrawal and sentenced him to 32 years with 4 years suspended.
Edwards appealed the denial of his motion to withdraw; the Court of Appeals affirmed, finding no abuse of discretion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Edwards)	Held
Whether the trial court abused its discretion by denying a motion to withdraw a guilty plea	The denial should be upheld; plea was voluntary, supported by written agreement and admissions, and no manifest injustice shown	Plea should be withdrawn because he lacked time to analyze exculpatory/implicating text and Facebook messages before pleading	Affirmed — no abuse of discretion; defendant failed to prove manifest injustice

Brightman v. State, 758 N.E.2d 41 (Ind. 2001) (sets standard that withdrawal should be allowed to correct a manifest injustice)
Coomer v. State, 652 N.E.2d 60 (Ind. 1995) (explains appellate review presumes trial-court ruling on plea-withdrawal is correct and is reviewed for abuse of discretion)