State Of Washington v. Jaylin J. Irish, 49113-3

In 2012 Irish was charged with multiple first-degree assault counts; on Sept. 10, 2013 he pleaded guilty to an amended information charging first-degree assault and first-degree rendering criminal assistance.
Irish signed a written plea statement saying the plea was made "freely and voluntarily" and the trial court conducted a plea colloquy and accepted the plea as knowing, intelligent, and voluntary.
At sentencing defense counsel reported Irish wanted to withdraw his plea, and counsel sought to withdraw due to a conflict; the trial court denied counsel’s withdrawal and imposed sentence. That denial was later held to violate Irish’s right to counsel, sentence vacated, and remanded for a CrR 4.2(f) withdrawal motion with new counsel.
With new counsel Irish moved to withdraw alleging he had been coerced by defense counsel to plead guilty because counsel said trial would likely result in 40–50 years and appeared unprepared. Irish testified he felt scared and had no alternative.
At the withdrawal hearing defense counsel denied coercion and testified he reviewed the plea thoroughly and was prepared for trial; the trial court found Irish’s plea voluntary and denied withdrawal.
Irish appealed; the Court of Appeals affirmed, holding the trial court did not abuse its discretion and Irish failed to meet the heavy burden to show his plea was involuntary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Irish’s guilty plea was involuntary due to coercion by his defense counsel	Irish: counsel pressured him to plead by predicting long exposure (40–50 yrs) and appearing unprepared, so plea was not knowing/voluntary	State: plea statement and on-the-record colloquy create a strong presumption of voluntariness; counsel denied coercion and testified he adequately advised Irish	Court: Affirmed — Irish failed to meet the heavy burden to show coercion; plea was voluntary after full consultation and adequate assistance
Whether trial court’s findings (FOF 5 & 6) lacked substantial evidence	Irish: records do not support findings that he decided of his own accord and that the court found plea knowing/voluntary	State: plea colloquy, written plea, and counsel’s testimony constitute substantial evidence	Court: Findings supported by substantial evidence (plea statement, colloquy, testimony)

Marshall v. State, 144 Wn.2d 266 (standard of review for plea-withdrawal abuse of discretion)
Frederick v. State, 100 Wn.2d 550 (subjective fear insufficient; heavy burden to show in-court admission was coerced)
Osborne v. State, 102 Wn.2d 87 (definitions of manifest injustice and voluntariness principles)
Davis v. State, 125 Wn. App. 59 (written plea + oral colloquy gives near-irrefutable presumption of voluntariness)
Zhao v. State, 157 Wn.2d 188 (deference to trial court on witness credibility)