State v. Gerald D. Taylor, 347 Wis. 2d 30

Taylor pled no contest to uttering a forgery as a repeater, facing a maximum of eight years due to the repeater enhancement.
At the plea hearing, the court stated a maximum six-year term (and a $10,000 fine) but did not explicitly inform Taylor of the additional two-year repeater penalty during the plea colloquy.
Taylor was sentenced to six years in prison; he later moved for postconviction relief to withdraw his plea under Wis. Stat. § 809.30(2)(h) arguing the plea colloquy was deficient.
The circuit court denied the Bangert hearing without proving the plea knowingly, intelligently, and voluntarily, deeming the error harmless since the sentence matched the discussed six years.
The court of appeals certified the appeal to the Wisconsin Supreme Court to resolve whether the misstatement constitutes harmless error and whether a Bangert hearing was required, given Cross and Brown precedent.
The court ultimately held the plea was entered knowingly, intelligently, and voluntarily, and denied withdrawal, applying Bangert and manifest-injustice standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a Bangert/Brown framework governs Bangert motions after sentencing.	Taylor argues for Bangert hearing under postconviction standard.	State argues manifest-injustice framework is controlling or harmless error analysis.	Bangert framework governs; plea denial not manifest injustice.
Whether failure to inform about the repeater-enhanced eight-year maximum was a Bangert violation.	Taylor contends missing the eight-year maximum at plea violated Bangert.	State contends record shows knowledge of eight-year max and error insubstantial.	No Bangert violation; record shows awareness of eight-year maximum; no evidentiary hearing required.
Whether withdrawal of the plea was necessary to correct a manifest injustice.	Taylor asserts manifest injustice due to lack of knowledge of the maximum penalty.	State argues no manifest injustice given actual six-year sentence and awareness of penalty.	Not necessary to withdraw; no manifest injustice.
Proper remedy if the error is an underinformed maximum penalty, not withdrawal.	Taylor seeks Bangert relief rather than commutation.	State advocates commuting the portion related to the repeater if necessary.	Remedy is not withdrawal; discrepancies do not require Bangert hearing; commute if needed, but here six years suffit.

State v. Bangert, 131 Wis. 2d 246 (1986) (establishes Bangert framework for plea withdrawals due to defective plea colloquies)
State v. Brown, 293 Wis. 2d 594 (2006) (requires court to explain nature of the charge and potential punishment; supports Bangert duty)
State v. Cross, 326 Wis. 2d 492 (2010) (guides due process analysis and limits of harmless error in plea colloquies)
State v. Reppin, 35 Wis. 2d 377 (1967) (manifest injustice framework; four foundational scenarios for plea withdrawal)
State v. Cain, 342 Wis. 2d 1 (2012) (clarifies manifest injustice framework and Bangert-related procedures post-sentencing)