State v. G. Enzler, 2017 MT 152N

Gary Lee Enzler pled guilty in 2011 to four counts of felony sexual assault of a minor; the district court conducted a plea colloquy and accepted the plea.
Pre‑sentence psychological evaluations by Dr. Smelko and Tracy Vaughn found Enzler competent and understanding at the time of the plea.
At sentencing the court deviated from the plea agreement, offered Enzler the chance to withdraw, and after consulting counsel Enzler declined; the court sentenced him to 45 years with 29 years suspended.
In January 2014 Enzler moved to withdraw his plea, claiming he pled because counsel told him to and that he was not in his “right mind.” Counsel sought a psychological evaluation and the court found Enzler unfit to proceed for purposes of the post‑sentencing proceedings.
At the May 4, 2015 hearing on the motion to withdraw, Enzler was present but did not testify; the district court denied the motion, focusing on Enzler’s competency at the 2011 change‑of‑plea hearing.
Enzler appealed the denial; the Montana Supreme Court reviewed voluntariness and competency standards and affirmed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Enzler’s 2011 guilty plea was voluntary and intelligent (competency at time of plea)	State: Plea was voluntary; colloquy, written plea, counsel, and pre‑sentence evaluations show competency	Enzler: Later mental health problems and claim that counsel told him to plead undermine voluntariness	Court: Plea was voluntary and intelligent; findings supported by substantial evidence (colloquy, written plea, counsel, evaluations)
Whether the district court violated due process by holding an evidentiary hearing while Enzler claimed unfitness to proceed (raised for first time on appeal)	State: Issue not preserved below; court need not address new claim on appeal	Enzler: Hearing while unfit violated due process (raised for first time on appeal)	Court: Declined to consider new claim on appeal (generally won’t entertain issues not raised below); did not apply plain‑error review here

State v. Usrey, 351 Mont. 341, 212 P.3d 279 (2009) (guilty plea must be voluntary and intelligent; competency requirement)
State v. Hendrickson, 375 Mont. 136, 325 P.3d 694 (2014) (standard of review for denial of motion to withdraw guilty plea)
State v. Peterson, 372 Mont. 382, 314 P.3d 227 (2013) (court generally will not consider issues raised for first time on appeal)
State v. Favel, 381 Mont. 472, 362 P.3d 1126 (2015) (plain‑error review is discretionary)