State v. Edwin Urbina (073209), 115 A.3d 261

In 2007, then-16-year-old Edwin Urbina shot and killed Edwin Torres; eyewitness identified Urbina and Torres had multiple gunshot wounds. Urbina surrendered and later elected transfer to the Law Division.
Urbina entered a negotiated guilty plea to first‑degree aggravated manslaughter (avoiding murder indictment) in exchange for a sentence recommendation of 17.5 years with an 85% parole disqualifier; plea form included a waiver of self-defense and appeal rights.
During the plea colloquy Urbina admitted shooting Torres multiple times, said he saw Torres and another man “pulling out their firearms,” reached for his gun and it “just went off,” and stated “I ain’t mean to kill him. I just wanted to have him back up.”
Defense counsel and the prosecutor told the court no weapon was recovered on the victim and that self-defense appeared nonviable; Urbina agreed with counsel and waived self‑defense on the record and in the amended plea paperwork.
Nearly three years later Urbina appealed, arguing the plea’s factual basis was inadequate because his statements suggested a claim of self-defense (a complete defense). The Appellate Division affirmed in a split decision; the New Jersey Supreme Court granted review.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Urbina)	Held
Whether the factual basis for Urbina’s guilty plea was inadequate because his plea colloquy suggested he was asserting self-defense (a complete defense)	The plea admissions established every element of aggravated manslaughter; Urbina’s remarks were exploratory or blame‑shifting, not a factual assertion of innocence, and he expressly waived self‑defense after consulting counsel and family.	Urbina contends his statements raised a contemporaneous claim of self‑defense; the court failed to probe his understanding of the law and the State’s burden to disprove self‑defense, so the plea may not have been knowing, intelligent, and voluntary.	The Court held the record lacked the necessary, thorough inquiry into the apparent assertion of self‑defense and whether Urbina understood that self‑defense would shift the burden to the State; the plea’s factual basis was therefore insufficient — plea vacated and case remanded.
Whether Urbina’s negotiated sentence was manifestly excessive	The State argued the sentence followed the plea agreement and was appropriate.	Urbina argued his sentence was excessive.	The Court did not disturb the sentence on the merits because it vacated the plea for insufficiency of the factual basis and remanded for further proceedings.

North Carolina v. Alford, 400 U.S. 25 (Supreme Court) (discusses plea of guilty while maintaining innocence and the need for a strong factual basis)
State v. Munroe, 210 N.J. 429 (N.J. 2012) (requires courts to explore whether a defendant has a potentially valid defense before accepting plea waivers)
State v. Handy, 215 N.J. 334 (N.J. 2013) (requires a thorough inquiry before accepting waiver of significant defenses/rights)
McCarthy v. United States, 394 U.S. 459 (Supreme Court) (guilty plea waives multiple constitutional rights and court must ensure voluntariness and factual basis)
State v. Perry, 124 N.J. 128 (N.J. 1991) (self‑defense requires an actual, honest, and reasonable belief; once raised, State must disprove beyond a reasonable doubt)
State v. Kelly, 97 N.J. 178 (N.J. 1984) (describes standards for self‑defense and jury instruction burden shifting)
State v. Slater, 198 N.J. 145 (N.J. 2009) (framework for evaluating motions to withdraw pleas)
State v. Campfield, 213 N.J. 218 (N.J. 2013) (plea courts must elicit a comprehensive factual basis addressing each element)
State v. Smullen, 118 N.J. 408 (N.J. 1990) (recognizes defendants’ reluctance to admit culpable details and permits leading questions to secure factual basis)
State v. Taccetta, 200 N.J. 183 (N.J. 2009) (rejects acceptance of perjured pleas and emphasizes need for truthful factual basis)