Snyder v. State, 346 P.3d 669

Snyder pleaded guilty to one count of sexual exploitation of a minor in exchange for the dismissal of nine counts and, after sentencing, he filed a notice of appeal but later voluntarily withdrew the appeal.
Snyder then filed a petition for postconviction relief seeking relief from his conviction on various grounds, including ineffective assistance of counsel.
The trial court granted summary judgment for the State, dismissing Snyder's postconviction petition, and Snyder appealed.
The court reviews summary judgment de novo and requires no genuine issue of material fact; the moving party must show entitlement to judgment as a matter of law, with the nonmoving party bearing the burden to set forth specific facts showing a genuine issue.
The court held that claims challenged to the conviction via a guilty plea are generally waived unless the plea was not voluntary or intelligent, and that many asserted issues were either waived, not preserved, or otherwise not supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does guilty-plea waiver bar postconviction challenges?	Snyder asserts postconviction relief on various grounds against the conviction.	State contends waiver applies and bars substantive postconviction challenges arising from the plea.	Waiver bars substantive postconviction claims arising from the plea.
Were Snyder's ineffective-assistance claims proven?	Snyder claims counsel was ineffective in pre- and post-plea proceedings.	State argues no deficient performance or prejudice is shown under Strickland/Menzies.	Snyder failed to show deficient performance or prejudice.
Was the pre-sentence report issue properly preserved?	Counsel allegedly failed to ensure the pre-sentence report was corrected.	Issue could have been raised on direct appeal and is barred post-appeal withdrawal.	Barred due to withdrawal of the direct-appeal and waiver.
Did counsel fail to move to withdraw Snyder's plea or adequately investigate the evidence?	Counsel did not pursue withdrawal or adequately evaluate the evidence.	Record shows Snyder waived the motion to withdraw and the investigation was reasonable under the circumstances.	No reversible error; waiver and sound strategy.
Is Snyder entitled to counsel in postconviction appellate proceedings?	Snyder seeks appointment of counsel for postconviction appeal.	No right to counsel in postconviction proceedings.	No entitlement to counsel in postconviction proceeding.

State v. Rhinehart, 167 P.3d 1046 (Utah Supreme Court, 2007) (plea-waived claims bar postconviction challenges)
Medel v. State, 184 P.3d 1226 (Utah Supreme Court, 2008) (standards for ineffective-assistance claims in postconviction)
Menzies v. State, 2014 UT 40 (Utah Supreme Court, 2014) (ineffective-assistance standard and deference to trial strategy)
Jaeger, 973 P.2d 404 (Utah Supreme Court, 1999) (addressing pre-sentence report challenges on direct appeal)
Nicholls v. State, 203 P.3d 976 (Utah Supreme Court, 2009) (appellate counsel considerations and procedural posture)
Hutchings v. State, 84 P.3d 1150 (Utah Supreme Court, 2003) (no entitlement to counsel in postconviction proceedings)
Wright, 43 F.3d 491 (10th Cir., 1994) (standards for ineffective assistance under Strickland)