State of Tennessee v. Corey E. Huddleston, M2017-00029-CCA-R3-CD

Defendant Corey E. Huddleston was indicted for aggravated burglary and sexual battery based on allegations he entered a minor’s bedroom and touched the child’s genitals.
On February 8, 2016 Huddleston pleaded no contest to sexual battery, received a one-year sentence, and the aggravated burglary charge was dismissed; he was to be placed on the sex offender registry.
At the plea colloquy Huddleston indicated he had not been told about the registry; the assistant public defender (substituting for the regular PD) explained registry consequences on the record; the court offered time to consult counsel and Huddleston declined and confirmed he wished to proceed.
Fourteen days later Huddleston filed a pro se motion to withdraw his plea, asserting he did not know he would be placed on the sex offender registry and would not have pleaded otherwise.
At the hearing on the motion, defense counsel admitted they had not discussed registry details; the trial court found Huddleston was educated, had opportunity to consult counsel, and that his plea was knowing and voluntary.
The trial court denied the motion to withdraw; Huddleston appealed and the Court of Criminal Appeals affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Huddleston)	Held
Whether Huddleston’s plea was knowingly, voluntarily, and understandingly entered such that post‑sentence withdrawal to correct manifest injustice is required	The plea was voluntary; court offered opportunity to confer and Huddleston declined further consultation	Plea was not informed because Huddleston did not know about the sex offender registry and counsel failed to advise him adequately	Affirmed: no manifest injustice; trial court did not abuse discretion
Whether trial court applied correct standard (Blankenship factors) in assessing voluntariness	Trial court applied relevant factors and made findings on record	Huddleston argued court failed to properly consider Blankenship factors	Held: Court considered relevant Blankenship factors and applied correct legal standard

State v. Phelps, 329 S.W.3d 436 (discussing standard of review for plea withdrawal)
State v. Crowe, 168 S.W.3d 731 (defendant has no unilateral right to withdraw plea; manifest injustice standard)
Blankenship v. State, 858 S.W.2d 897 (factors for determining whether plea was knowing, voluntary, and understanding)
State v. Virgil, 256 S.W.3d 235 (examples of circumstances establishing manifest injustice)
Powers v. State, 942 S.W.2d 551 (quoting Blankenship factors)