State v. Craig, 941 N.W.2d 539

Russell Craig was charged with murder (class AA felony) in 2006, pled guilty (open plea) in January 2007, and was sentenced to life with the possibility of parole in March 2007.
A DOCR case plan and Craig’s 2007 letter reflected his belief he would be parole-eligible after about 20–23 years; statutory parsing and court materials reflected a different calculation (85% of remaining life expectancy and a 30-year parole-ineligibility rule).
In 2018 Craig moved to withdraw his guilty plea, claiming he did not knowingly waive rights because he misunderstood parole eligibility; the district court initially denied without a hearing, this Court remanded for a hearing, and the district court again denied relief after a hearing.
Craig raised additional arguments on appeal (illegal sentence and ex post facto violation) that were not presented below; the Supreme Court declined to address those claims because Craig did not argue obvious error.
The Supreme Court held Craig’s plea was knowingly and voluntarily entered: the plea was an open plea with a non-binding state recommendation, Craig was told he could receive 0 to life without parole, and he had been informed elsewhere in the proceedings of the 30-year parole-ineligibility rule.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Craig may withdraw his guilty plea because it was not knowing, intelligent, and voluntary due to misunderstanding parole eligibility	The State: Craig knew plea was open, was told court could impose 0 to life without parole, and a mistaken belief about parole timing is not manifest injustice	Craig: He relied on DOCR case plan and earlier statements that suggested parole eligibility after ~20 years, so his plea was not knowing/voluntary	Denied — no manifest injustice: plea was based on a non-binding recommendation, Craig was warned plea could result in 0–life, and he had been informed of the 30-year parole-ineligibility elsewhere
Whether the sentence was illegal or violated the ex post facto clause	State: statutory scheme properly applied (85% calculation and 30-year parole-ineligibility)	Craig: Sentence calculation and post-hoc rules made his sentence illegal/ex post facto	Not considered on appeal — Craig did not raise these issues below and did not argue obvious error
Whether the court was required at the change-of-plea hearing to re-state the 30-year parole-ineligibility provision	State: Not required; prior advisements suffice and Houle supports voluntariness despite omission	Craig: Court should have explicitly advised at plea hearing about the 30-year parole ineligibility	Held — not required; prior advisements were adequate and omission did not render plea involuntary

State v. Sah, 938 N.W.2d 912 (discusses the obvious-error standard for issues not raised below)
State v. Hart, 569 N.W.2d 451 (addresses preservation of issues for appeal)
State v. Thomas, 938 N.W.2d 897 (related to obvious-error review principles)
State v. Peterson, 927 N.W.2d 74 (requires substantial compliance with Rule 11 to ensure voluntary pleas)
State v. Yost, 914 N.W.2d 508 (explains Rule 11 substantial-compliance and plea voluntariness)
State v. Garge, 818 N.W.2d 718 (discusses abuse-of-discretion review for plea-withdrawal denials)
State v. Feist, 708 N.W.2d 870 (distinguishes non-binding recommendations from binding plea agreements)
Houle v. State, 482 N.W.2d 24 (holding that failure to advise of parole-eligibility provision does not necessarily affect plea voluntariness)