State of Minnesota v. Frank Henry Stanhope, A16-84

Background

Frank Stanhope was charged with first-degree possession of methamphetamine and rejected multiple plea offers before pleading guilty without a sentencing agreement.
He signed a plea petition stating the agreement was a "straight plea to Judge" with defense to argue for a downward dispositional departure; he acknowledged no guarantee of a departure and that he gave up the right to challenge admissibility of evidence.
Prior to sentencing Stanhope retained new counsel and moved to withdraw his guilty plea, alleging manifest injustice based on ineffective assistance and that he was induced by illusory promises about sentencing and appeal rights.
The district court denied the suppression motion earlier, denied plea withdrawal, denied a downward departure, and sentenced Stanhope to 120 months in prison.
The court found Stanhope’s plea was voluntary, intelligent, and inconsistent with his later claims that he was induced by promises; it also credited plea-colloquy statements over unsworn assertions by new counsel.

Issues

Issue	Stanhope's Argument	State's Argument	Held
Whether plea withdrawal is required because the plea was invalid (manifest injustice)	Plea was involuntary/intelligent because counsel and the state induced an "illusory" promise of a chance at probation and ability to appeal the pretrial evidentiary ruling	Plea was valid: no sentencing promise from state; plea petition and colloquy show Stanhope understood no guarantees and waived challenge to pretrial rulings	Denied — plea was voluntary, intelligent, and not rendered invalid by any illusory promise
Whether plea withdrawal should be allowed under the lower "fair and just" standard before sentencing	If plea is invalid it also satisfies the fair-and-just standard	District court gave due consideration and found no fair-and-just basis; state argued withdrawal would undermine plea integrity	Denied — district court did not abuse discretion under the fair-and-just standard
Whether attorney advice about probability of departure or appeal rendered plea unintelligent	Counsel’s email and alleged statements misled Stanhope into pleading	Record lacks evidence counsel misinformed defendant; Stanhope did not raise ineffective-assistance claim on appeal	Denied — no basis to second-guess counsel’s advice and defendant did not pursue IAC claim
Whether a defendant can appeal pretrial rulings after pleading guilty	Stanhope contends he was told he could still appeal the pretrial evidentiary ruling after pleading guilty	Generally a guilty plea waives non-jurisdictional pretrial defects; record (plea petition/colloquy) contradicts claim of being told appeal remained	Denied — no evidence he was told he could appeal; plea waived such challenges

Key Cases Cited

State v. Theis, 742 N.W.2d 643 (Minn. 2007) (standards for plea withdrawal)
State v. Raleigh, 778 N.W.2d 90 (Minn. 2010) (plea validity requires accuracy, voluntariness, intelligence)
Perkins v. State, 559 N.W.2d 678 (Minn. 1997) (criteria for valid guilty plea)
Kim v. State, 434 N.W.2d 263 (Minn. 1989) (fair-and-just standard and plea-integrity concerns)
State v. Ford, 397 N.W.2d 875 (Minn. 1986) (guilty plea waives non-jurisdictional pretrial defects)
State v. Wukawitz, 662 N.W.2d 517 (Minn. 2003) (state bears burden to show prejudice from plea withdrawal)