State v. Hamilton, 999 N.W.2d 214

Michael Dean Hamilton was charged with hindering law enforcement, accused of providing transportation and money to someone involved in an abduction in Virginia.
A plea agreement was initially presented to the district court; the court rejected this after finding the factual basis insufficient.
Parties later submitted a written plea agreement; the court again rejected it, requiring any subsequent plea to be an open one.
Hamilton then entered an open guilty plea, acknowledging there was enough evidence for a jury to convict (effectively an Alford plea).
On appeal, Hamilton challenged both the rejection of the original plea agreement and the sentencing process, claiming reliance on impermissible factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
District court’s rejection of plea agreement	Court was within its discretion to reject insufficient factual basis.	District court abused discretion by rejecting plea, then accepting later open plea on similar facts.	Waived by Hamilton's knowing, voluntary open plea; no review of non-jurisdictional defects.
Reliance on impermissible sentencing factors	Court properly used facts and inferences at sentencing; no clear prohibition.	Sentencing relied on facts outside the record and unreasonable inferences, making it illegal.	No obvious error; sentencing court may consider a broad range of information and reasonable inferences.

State v. Wallace, 918 N.W.2d 64 (N.D. 2018) (a defendant who voluntarily pleads guilty generally waives challenges to non-jurisdictional defects)
State v. Trevino, 807 N.W.2d 211 (N.D. 2011) (scope of appeal after open guilty plea)
State v. Thomas, 938 N.W.2d 897 (N.D. 2020) (abuse of discretion standard for sentencing review)
State v. Clark, 818 N.W.2d 739 (N.D. 2012) (sentencing review limited to statutory limits or impermissible reliance)
State v. Gardner, 992 N.W.2d 535 (N.D. 2023) (no obvious error without clearly established law against the action)