State v. DeAnda, 411 P.3d 330

In 2008 Joaquin DeAnda (then 17) was charged with first-degree murder, rape, and aggravated criminal sodomy after a 16-year-old girl's body was found; he pleaded guilty to first-degree premeditated murder in exchange for dismissal of other counts.
The district court accepted the plea, found aggravating circumstances, and sentenced DeAnda to life with a hard 50-year minimum; this Court vacated the hard-50 sentence and remanded for resentencing under Alleyne.
On remand DeAnda filed a presentence motion to withdraw his guilty plea, alleging ineffective or inadequate counsel, that his mental-health status and the plea process coerced him, and that his plea was not knowing and voluntary.
The district court held an evidentiary hearing, considered mental-health evaluations and testimony from DeAnda and his former counsel (Freeman-Johnson), and denied the motion, finding counsel competent, no coercion or unfair advantage, and the plea knowing and voluntary.
DeAnda appealed; the Supreme Court reviewed for abuse of discretion (applicable standard for K.S.A. 2016 Supp. 22-3210(d)(1)) and affirmed the district court's denial of the motion to withdraw the plea.

Issue	Plaintiff's Argument (DeAnda)	Defendant's Argument (State)	Held
Standard of review	DeNovo because due process implicated	Abuse of discretion applies to plea-withdrawal under K.S.A. 22-3210(d)(1)	Abuse of discretion standard applies
Competence of counsel	Counsel relied on a snapshot of competency and provided lackluster advocacy supporting withdrawal	Record shows repeated consultation, retained experts, extensive preparation—counsel competent	District court did not abuse discretion; counsel was competent
Coercion / undue pressure from mental-health state and process	Fluctuating competency evaluations and fragile mental state created a ‘‘perfect storm’’ that pressured plea	Court and counsel addressed mental-health issues repeatedly; plea colloquy and evaluations show informed decision	No coercion or unfair advantage; district court's finding upheld
Voluntariness / knowing plea	Cognitive, emotional, developmental problems meant plea may not have been understandingly entered	Plea colloquy, written agreement, and testimony demonstrate DeAnda understood charges, rights, and consequences	Plea was knowing, voluntary, and understanding; denial affirmed

Alleyne v. United States, 570 U.S. 99 (jury must find aggravating facts required for increased mandatory minimum)
State v. Edgar, 281 Kan. 30 (factors for determining good cause to withdraw plea)
State v. Reu-El, 306 Kan. 460 (appellate review of plea-withdrawal denial is for abuse of discretion)
State v. Aguilar, 290 Kan. 506 (Edgar factors and competence-of-counsel guidance)
State v. Schaefer, 305 Kan. 581 (trial court's opportunity to observe defendant in plea colloquy relevant to voluntariness)
State v. Ward, 292 Kan. 541 (definition of abuse of discretion)