State of Maine v. John P. Stevens, 2017 ME 30

Stevens was indicted for receiving stolen property (sale of CMP copper wire).
On the day of trial, with a jury selected, Stevens entered an unconditional (open) guilty plea with counsel present; the court conducted a Rule 11 inquiry.
Stevens did not move to withdraw the plea before sentencing; six weeks later the court sentenced him to four years’ imprisonment (plus concurrent misdemeanor sentences).
Stevens appealed, arguing the Rule 11 colloquy was incomplete because the court did not ask whether he understood consequences of any prior plea negotiations.
The State moved to dismiss the appeal; the court considered the motion and the merits threshold issue together.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a defendant may directly appeal from an unconditional guilty plea on grounds that the Rule 11 colloquy failed to confirm awareness of plea negotiations	Stevens: court was required to ask whether he was aware of and understood consequences of any plea negotiations, so plea may be involuntary	State: direct appeal is improper for challenges to voluntariness/noncompliance with Rule 11 absent jurisdictional or sentencing-constitution claims or a pre-sentencing withdrawal motion	Appeal dismissed; such Rule 11/nonvoluntariness claims are collateral and must be pursued by post-conviction review (no jurisdictional or constitutional sentencing challenge; plea not withdrawn)

State v. Huntley, 676 A.2d 501 (Me. 1996) (direct appeals from unconditional guilty pleas limited to jurisdiction or unconstitutional punishment; other challenges are collateral)
State v. Plummer, 939 A.2d 687 (Me. 2008) (reaffirming Huntley; absent conditional plea or pre-sentencing withdrawal, appeal dismissed unless jurisdiction or sentencing-constitution challenged)
State v. Pfeil, 720 A.2d 573 (Me. 1998) (post-conviction review required because evidentiary hearing is necessary to assess knowing and voluntary plea)
State v. Gach, 901 A.2d 184 (Me. 2006) (dismissing direct appeal from unconditional guilty plea for same reasons)