State of Minnesota v. Adaiah Deontraie Townsend, 2015 Minn. App. LEXIS 87

Townsend pled guilty to aiding an offender after the fact to Shufford’s murder and testified against Shufford at trial.
The gun Townsend lent was used by Shufford to commit the murder, and Townsend knew the gun had been used to kill the victim.
Shufford’s trial resulted in a not guilty verdict for the underlying murder.
Townsend moved to withdraw the plea before sentencing; the district court denied the motion.
Townsend argues the factual basis was inaccurate because the principal’s guilt was not proven beyond a reasonable doubt, given the jury’s acquittal of Shufford.
The court ultimately held Townsend’s plea was accurate and affirmed the denial of withdrawal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there manifest injustice to withdraw the plea?	Townsend	Townsend	No manifest injustice; plea accurate and valid.
Did the district court abuse discretion under fair-and-just standard?	Townsend	Townsend	No abuse; reasons insufficient to justify withdrawal.

State v. Farnsworth, 738 N.W.2d 364 (Minn. 2007) (guidelines for withdrawing guilty plea; manifest injustice standard)
State v. Raleigh, 778 N.W.2d 90 (Minn. 2010) (manifest injustice and fair-and-just standards for withdrawal)
Lussier v. State, 821 N.W.2d 581 (Minn. 2012) (sufficiency of factual basis for plea must support charge)
State v. Hager, 727 N.W.2d 668 (Minn. App. 2007) (amendment to statute allowing knowledge or reason to know)
State v. Cegon, 309 N.W.2d 313 (Minn. 1981) (acquittal of principal does not negate aiding conviction)
State v. Iverson, 396 N.W.2d 599 (Minn. App. 1986) (application of Cegon to aiding cases)
Standefer v. United States, 447 U.S. 10 (1980) (collateral concerns; nonmutual collateral estoppel in crimes)