State v. Coulter, 2016 MT 303N

In June 2014 Freddie Coulter III (age 21) was charged with one count of felony sexual assault and two counts of felony sexual abuse of children based on a sexual encounter with C.A. (age 11).
In December 2014 Coulter pled guilty to sexual assault pursuant to a plea agreement; the two child-abuse counts were dismissed.
In February 2015 the District Court sentenced Coulter to 20 years with 10 years suspended, conditioned parole eligibility on completion of sexual-offender treatment, and imposed fines and restrictions.
In August 2015 Coulter moved to withdraw his guilty plea, asserting (1) he did not "knowingly" commit sexual assault because he claimed C.A. had represented she was over 18, and (2) his counsel misadvised/induced him into pleading guilty.
The District Court denied the motion, finding Coulter had not shown "good cause" to withdraw the plea, that his factual admissions established the offense elements, and that counsel’s advice fell within competent representation.
Coulter appealed; the Supreme Court reviewed the denial for factual-error and legal correctness and reviewed ineffective-assistance claims de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Coulter showed good cause to withdraw his guilty plea	State: Coulter’s admissions established elements; no good cause shown	Coulter: Plea involuntary because he lacked knowledge that victim was a minor; believed victim claimed to be 18	Denied — no good cause; plea voluntary and supported by admissions
Whether proof required that Coulter knew victim was under 18	State: Knowledge of age not required; element is knowingly engaging in sexual contact and lack of consent shown by victim’s age	Coulter: He believed victim was over 18, so could not knowingly commit offense	Held for State — knowledge of victim’s age not required; lack of consent established by statutory incapacity of victim under 14 when offender is ≥3 years older
Whether counsel’s advice amounted to ineffective assistance inducing the plea	State: Counsel reviewed elements, penalties, and advice was within competent range	Coulter: Counsel misadvised him about his defenses and induced plea	Held for State — counsel’s performance within acceptable range; no prejudice shown
Standard for reviewing motion to withdraw plea and IAC on plea	State: District Court applied correct standards	Coulter: Challenged application and findings	Held: District Court findings supported and legal standards correctly applied; appellate review affirms

State v. LeMay, 266 P.3d 1278 (Mont. 2011) (voluntariness of plea depends on whether counsel’s advice was within range of competence)
State v. Hendrickson, 325 P.3d 694 (Mont. 2014) (standard of review for denial of motion to withdraw guilty plea—factual findings for clear error; legal questions reviewed for correctness)
State v. Kougl, 97 P.3d 1095 (Mont. 2004) (ineffective-assistance-of-counsel claims reviewed de novo)