State of Tennessee v. David Nagele, 353 S.W.3d 112

Defendant David Nagele pled guilty to attempted aggravated sexual battery, receiving six years of enhanced probation.
Lifetime community supervision was mandated by statute but not mentioned in plea, judgment form unchecked.
State filed a petition to amend judgment to include lifetime supervision shortly before sentence expiration.
Defendant moved to withdraw his guilty plea after the judgment was corrected.
Court of Criminal Appeals affirmed that counsel adequately advised about lifetime supervision; Tennessee Supreme Court granted review.
Ward v. State was decided after the CCA opinion, creating the issue of whether the error was harmless and whether withdrawal should be allowed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court’s failure to warn about lifetime supervision was harmless beyond a reasonable doubt	Nagele	Nagele contends error not harmless due to uncertain counsel advice	No, not harmless beyond a reasonable doubt
Did trial counsel’s testimony establish harmless error	State	Counsel implied awareness but not definite disclosure	Not clearly establishing harmlessness; issue remanded for withdrawal consideration
Whether the guilty plea should be withdrawn for manifest injustice	State	Plea obtained without full understanding of mandatory life supervision	Yes; withdrawal granted and remand for plea withdrawal

Ward v. State, 315 S.W.3d 461 (Tenn. 2010) (mandatory lifetime supervision is a direct consequence requiring notice)
Neal, 810 S.W.2d 131 (Tenn. 1991) (harmless error standard for direct consequences)
Blankenship v. State, 858 S.W.2d 897 (Tenn. 1993) (direct consequences and knowing plea standards)
Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (requirement that plea be voluntary and intelligent)
Grindstaff v. State, 297 S.W.3d 208 (Tenn. 2009) (factors for knowingly and voluntarily entering a guilty plea)
Ward v. State, 315 S.W.3d 467 (Tenn. 2010) (defined direct consequence and duty to inform before plea)