State of Minnesota v. Titus Triston Miguel Mangun, A16-105

Mangun was charged with first- and third-degree controlled-substance crimes based on two undercover heroin sales (April 15 and May 1, 2015) and a subsequent search that recovered 44 grams of heroin from an apartment.
First-degree count was amended to aiding and abetting first-degree controlled-substance crime; third-degree count was dismissed; Mangun pleaded guilty to the amended charge on July 7, 2015.
Before sentencing, Mangun submitted pro se letters and moved to withdraw his plea, claiming innocence, insufficient factual basis, and ineffective assistance/confusion at the plea hearing.
The district court denied the motion to withdraw the plea at sentencing; it imposed an 80-month downward durational departure from the presumptive 122-month sentence.
On appeal, Mangun argued (1) the factual basis for his plea was insufficient (plea inaccurate/manifest injustice) and (2) the court abused its discretion under the fair-and-just standard given his alleged confusion and counsel performance.
The Court of Appeals affirmed, finding the plea had an adequate factual basis and the district court did not abuse its discretion under the fair-and-just standard.

Issue	Plaintiff's Argument (Mangun)	Defendant's Argument (State)	Held
Sufficiency of factual basis / plea accuracy	Plea lacked adequate factual basis; answers were led by court and therefore inaccurate	Plea admissions established elements of aiding and abetting first-degree sale >10g within 90 days	Court: Factual admissions (controlled buys, source apartment, matching heroin, 44g recovered, aiding sale) suffice; plea accurate; no manifest injustice
Fair-and-just withdrawal (pre-sentencing)	Plea entered under confusion/"unsure heart"; counsel ineffective; searched property not his; backpack not proven his	State noted minimal prejudice (stopped trial prep; witness memory) and argued Mangun gave assurances at plea of adequate counsel and understanding	Court: Defendant failed to meet burden to show fair-and-just reason; denial of withdrawal not an abuse of discretion

State v. Raleigh, 778 N.W.2d 90 (Minn. 2010) (plea validity requires accuracy, voluntariness, and intelligence)
State v. Theis, 742 N.W.2d 643 (Minn. 2007) (fair-and-just standard for plea withdrawal is less demanding than manifest injustice but not unlimited)
Munger v. State, 749 N.W.2d 335 (Minn. 2008) (adequate factual basis must show defendant’s conduct fits the charged offense)
State v. Farnsworth, 738 N.W.2d 364 (Minn. 2007) (defendant bears burden to show fair-and-just reason to withdraw plea; review for abuse of discretion)
State v. Cubas, 838 N.W.2d 220 (Minn. App. 2013) (factors for fair-and-just withdrawal: defendant’s reasons and prejudice to prosecution)