State of Minnesota v. Joseph Gordon Ranniger
A15-1953
| Minn. Ct. App. | Dec 5, 2016Background
- Defendant Joseph Ranniger entered an Alford plea to one count of first-degree criminal sexual conduct involving his minor stepdaughter (acts alleged 2000–2011).
- At plea colloquy Ranniger acknowledged understanding his rights, that he had reviewed the evidence, and that there was a "substantial likelihood" he could be convicted, while maintaining innocence.
- Ranniger stipulated that the criminal complaint "substantially outlines" the evidence the state would present at trial.
- The district court accepted the Alford plea after finding the complaint provided an adequate factual basis and that the evidence was likely sufficient to convict.
- At sentencing Ranniger moved to withdraw the plea claiming it was invalid; the district court denied the motion and sentenced him to 144 months. Ranniger appealed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Ranniger) | Held |
|---|---|---|---|
| Whether Ranniger's Alford plea was valid (accurate, voluntary, intelligent) | The plea was valid because the complaint, as stipulated by Ranniger, provided an adequate factual basis and Ranniger admitted a "substantial likelihood" of conviction | The plea was invalid: the record lacked sufficient evidence and Ranniger did not agree on the record that the state's evidence was sufficient to convict | Court affirmed: plea valid—complaint supplied adequate factual basis and Ranniger agreed the evidence was sufficient ("substantial likelihood") |
Key Cases Cited
- State v. Theis, 742 N.W.2d 643 (Minn. 2007) (district court must ensure factual basis and defendant's agreement that evidence would be sufficient to convict in Alford plea)
- Perkins v. State, 559 N.W.2d 678 (Minn. 1997) (guilty plea must be accurate, voluntary, and intelligent)
- State v. Ecker, 524 N.W.2d 712 (Minn. 1994) (court must determine adequate factual basis for Alford pleas)
- State v. Goulette, 258 N.W.2d 758 (Minn. 1977) (recognition of Alford/Goulette pleas in Minnesota)
- Williams v. State, 760 N.W.2d 8 (Minn. App. 2009) ("substantial likelihood" language adequate for plea accuracy)
- State v. Farnsworth, 738 N.W.2d 364 (Minn. 2007) (no absolute right to withdraw valid plea)
- Roby v. State, 547 N.W.2d 354 (Minn. 1996) (court need not address alternative grounds not raised on appeal)
- North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (Supreme Court recognition of guilty plea while maintaining innocence)