State v. Damien A. Candland
309 P.3d 230
Utah2013Background
- Candland pled guilty to aggravated murder and aggravated assault in two unrelated incidents.
- Plea affidavit described the aggravated murder factual basis: defendant bound his aunt with duct tape and murdered her to retaliate against her testimony and to deter participation in proceedings.
- Aunt had been a witness against Candland in prior cases, providing motive for retaliation and to prevent testimony.
- Plea colloquy explained the charges, elements, and waivers of rights; the court stated the facts were sufficient and Candland could not appeal that point.
- After the hearing Candland sent handwritten letters seeking to withdraw his plea; the district court denied the motion and Candland appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the plea knowingly and voluntarily made? | Candland argues he did not understand the facts-law relation. | Court followed rule 11 and ensured understanding. | Yes; plea knowingly and voluntarily made. |
| Was Candland adequately informed about his right to appeal? | Notice to appeal rights was defective. | Plea affidavit complied with rule 11 advising waiver of appeal. | Yes; notice adequate. |
| Did the court err in assessing Candland's subjective understanding of the facts to the law? | Candland was confused about the aggravated murder facts and law. | Record shows understanding of facts and law; hesitancy related to aggravated assault, not murder. | No error; knowingly and voluntarily entered plea. |
Key Cases Cited
- McCarthy v. United States, 394 U.S. 459 (1969) (plea must be voluntary and knowledgable under due process)
- Bradshaw v. Stumpf, 545 U.S. 175 (2005) (awareness of charges and elements required for validity)
- Brady v. United States, 397 U.S. 742 (1970) (sufficient awareness of circumstances and likely consequences required)
- Boykin v. Alabama, 395 U.S. 238 (1969) (record must show awareness of rights waived in guilty plea)
- Hill v. Lockhart, 474 U.S. 52 (1985) (solicitude in canvassing plea waivers and consequences)
