State v. Desiree Rose Garner
Background
- Police stopped Garner for a loose license plate; officer found a passenger who admitted to marijuana and asked Garner to exit the vehicle.
- Garner told the officer she had drugs in her purse; police recovered methamphetamine and charged her with possession of a controlled substance (methamphetamine).
- Garner pled guilty while represented by a public defender, completing a guilty plea advisory form and orally confirming she was satisfied with counsel and understood rights and consequences at the plea hearing.
- After sentencing, Garner hired new counsel and moved to withdraw her guilty plea, alleging she has a learning disability, felt pressured/embarrassed into pleading, had been using methamphetamine around the plea time, and that her passenger had placed the drugs in her purse.
- At evidentiary hearings, Garner testified she was confused and pressured; her prior public defender testified about meetings and that Garner never said the passenger put meth in her purse.
- The district court found Garner’s plea was knowing, intelligent, and voluntary and that she had not shown a just reason to withdraw the plea; it denied the motion and sentenced her to a suspended unified five-year term with probation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plea was knowing, intelligent, and voluntary | State: plea colloquy and form show voluntariness | Garner: learning disability, recent meth use, felt pressured/embarrassed, confused about plea form | Court: plea was constitutionally valid; voluntariness inferred from record |
| Whether Garner knowingly waived rights | State: waiver confirmed on form and orally | Garner: did not fully understand rights due to confusion and pressure | Court: waiver knowingly made; court personally addressed rights and mental state |
| Whether there is a just reason to withdraw plea | State: no just reason shown; claim passenger planted drugs inconsistent and not raised earlier | Garner: claims passenger planted meth and other fairness concerns | Court: Garner failed to show just cause; contemporaneous admission and dual-possession law undermine planting claim |
| Whether denial of withdrawal was abuse of discretion | State: district court acted within discretion | Garner: district court should have allowed withdrawal given alleged defects | Court: no abuse of discretion; denial affirmed |
Key Cases Cited
- State v. Freeman, 110 Idaho 117, 714 P.2d 86 (Ct. App. 1986) (standard: withdrawal of plea lies in district court discretion)
- State v. Hanslovan, 147 Idaho 536, 211 P.3d 775 (Ct. App. 2008) (first inquiry: whether plea was knowing, intelligent, and voluntary)
- State v. Rodriguez, 118 Idaho 957, 801 P.2d 1308 (Ct. App. 1990) (same standard for plea withdrawal procedure)
- State v. Anderson, 156 Idaho 230, 322 P.3d 312 (Ct. App. 2014) (three-part inquiry for plea voluntariness: understanding of charges/coercion; waiver of trial/confrontation/self-incrimination rights; understanding consequences)