Rodrigo Castillo Trudillo v. State of Indiana (mem dec.), 12A04-1704-CR-831

In 2015 police investigated allegations by then-10-year-old A.S. that a man had inserted a finger into her vagina; Trudillo (the victim’s mother’s boyfriend) waived Miranda rights and admitted to a single touching in a recorded statement.
Trudillo was charged with Level 1 felony child molesting; after a year of discovery he signed a plea agreement pleading guilty to two Level 3 child-molesting counts (Level 1 dismissed). The agreement required at least ten years in the DOC but left exact sentence to the court.
At the plea hearing Trudillo received Spanish interpretation and advisements, initially expressed understanding, briefly answered “Not guilty” to one count, took a recess to consult counsel, and then unequivocally pleaded guilty and admitted the factual basis.
Months later Trudillo moved to withdraw the plea, claiming coercion (detective said an admission would "persuade the victim"), innocence, and relying on the victim’s later recantation at sentencing. He also raised concerns about lack of medical testing.
The trial court denied the motion, finding the plea was knowing and voluntary, the victim’s recantation reflected pressure from her mother (possibly from the defendant), and the State would be substantially prejudiced by withdrawal after delay. Trudillo received concurrent 12-year terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying Trudillo's motion to withdraw his guilty plea	State: plea was knowing, voluntary, and supported by a factual basis; defendant failed to prove manifest injustice and State would be prejudiced by withdrawal	Trudillo: plea resulted from coercion by detective and was unjust because the victim later recanted; he is innocent and should be allowed to withdraw	Affirmed: plea was knowing and voluntary; defendant failed to prove manifest injustice; trial court could credit victim-pressure explanation and found prejudice to the State

Moshenek v. State, 868 N.E.2d 419 (Ind. 2007) (trial court best positioned to weigh credibility and evidence)
Brightman v. State, 758 N.E.2d 41 (Ind. 2001) (presumption in favor of trial court’s ruling on plea-withdrawal motion)