State v. Bricker, 252 P.3d 118

Bricker pled no contest to aggravated battery (felony), DUI (misdemeanor), and failure to present proof of insurance (misdemeanor); sentences were 36 months in prison for the felony and 180 days for each misdemeanor, all concurrent.
Plea agreement recommended Labette Bootcamp Probation (LCCC); the State also discussed alternative sentences, but the agreement was silent on the insurance misdemeanor.
Bricker was screened for LCCC and found ineligible due to medication; the court later sentenced Bricker to prison.
Bricker's post-sentence motion claimed ineffective assistance of counsel for failing to determine LCCC eligibility and to discuss fallback options; trial court denied it, and the Court of Appeals affirmed.
On discretionary review, the Kansas Supreme Court affirmed, focusing on standards for plea withdrawal and ineffective assistance claims.
Key issue: whether Bricker demonstrated manifest injustice to withdraw his plea after sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bricker's post-sentence motion to withdraw plea was properly denied.	Bricker (Bricker) asserts manifest injustice due to counsel's failures.	State contends no abuse of discretion; no manifest injustice.	District court's denial affirmed; no manifest injustice.
Whether counsel's failure to learn LCCC criteria constitutes ineffective assistance under Strickland.	Bricker argues deficiency and prejudice under Strickland.	State contends no deficiency; Bricker understood screening was not guaranteed.	No constitutional deficiency; no prejudice shown.
Whether counsel failed to advise Bricker of the option to withdraw plea before sentencing.	Bricker contends failure to inform about withdrawal rights affected outcome.	State argues not showing reasonable probability of different result.	Failure to advise did not produce reasonable probability of withdrawal outcome.
Whether combining LCCC-related issues with plea-withdrawal analysis affects manifest injustice.	Aggregation could show manifest injustice.	No independent constitutional deficiency or manifest injustice.	No separate manifest injustice; aggregation does not modify result.

State v. Edgar, 281 Kan. 30, 127 P.3d 986 (2006) (Edgar factors guide manifest-injustice analysis)
State v. Aguilar, 290 Kan. 506, 231 P.3d 563 (2010) (Strickland standard applied to postconviction claims with caution)
State v. Gleason, 277 Kan. 624, 88 P.3d 218 (2004) (counsel's performance when evaluating plea options)
State v. Muriithi, 273 Kan. 952, 46 P.3d 1145 (2002) (applies Strickland standard to ineffective assistance)
State v. Sanchez-Cazares, 276 Kan. 451, 78 P.3d 55 (2003) (post-sentencing withdrawal standards)