State v. Adams, 184 A.3d 875

In Feb 2015 Adams was indicted for murder and Class A manslaughter after his infant son's death; two attorneys were appointed and a jury trial was set for Feb 17, 2017.
On Feb 8, 2017 Adams entered an unconditional open guilty plea to manslaughter; the State later dismissed the murder count. The court conducted a Rule 11 colloquy in which the State recited anticipated trial evidence, including Adams's statements about causing bruises on the child.
At the plea and again at sentencing Adams affirmed that he was pleading guilty because he was guilty, denied threats or promises, and stated his plea was voluntary; he did not move to withdraw the plea before sentencing.
At sentencing the court and parties discussed differences between the State’s Rule 11 factual recitation and Adams’s sentencing memorandum (which suggested injuries may have resulted from resuscitation). Counsel reaffirmed that Adams accepted responsibility for causing the death.
The court imposed a 20-year sentence with all but 15 years suspended and six years probation; Adams timely appealed and was ordered to show cause why his appeal should not be dismissed under State v. Huntley.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Adams’s guilty plea was involuntary because he was coerced (compelled to accept the State’s factual recitation, implicating self-incrimination)	Adams: plea was coerced and involuntary because he was pressured to accept the State’s recitation of facts and thus forced to incriminate himself	State/Court: defendant entered an unconditional plea, did not move to withdraw it, and Huntley bars direct appeals challenging plea voluntariness; such claims are collateral	Court: Appeal dismissed under Huntley; involuntariness/ coercion claims must be pursued via post-conviction review (PCRA)
Whether the court’s show-cause procedure or denial of a right to appointed fresh appellate counsel to search for appealable issues was improper	Adams: a routine appeal with fresh appellate review is needed to protect rights and discover rare appealable issues	Court: show-cause is an appropriate, settled method; if trial counsel missed a preserved appealable issue, that can be remedied in post-conviction proceedings; no entitlement to a direct appeal absent jurisdictional or sentencing illegality	Court: show-cause requirement and denial of interlocutory appellate review appropriate; no right to direct appeal absent the limited Huntley exceptions

State v. Huntley, 676 A.2d 501 (Me. 1996) (direct appeals from unconditional guilty pleas barred except for jurisdictional or sentencing-constitution claims; voluntariness and related claims are collateral)
State v. Plummer, 939 A.2d 687 (Me. 2008) (applying Huntley to bar direct appeal where plea was unconditional and no motion to withdraw was made)
State v. Gach, 901 A.2d 184 (Me. 2006) (applying Huntley to voluntariness/waiver claims after unconditional plea)
State v. Stevens, 156 A.3d 131 (Me. 2017) (dismissing direct appeal alleging the court failed to establish plea voluntariness under Huntley)
State v. Bean, 184 A.3d 373 (Me. 2018) (discussing limits on direct appeal from guilty pleas and sentencing-illegality review)
State v. Davenport, 138 A.3d 1205 (Me. 2016) (direct appeal from guilty plea may challenge facially apparent illegal sentence)