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State v. Damien A. Candland
309 P.3d 230
Utah
2013
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Background

  • 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)
Read the full case

Case Details

Case Name: State v. Damien A. Candland
Court Name: Utah Supreme Court
Date Published: Aug 16, 2013
Citation: 309 P.3d 230
Docket Number: 20110738
Court Abbreviation: Utah