State v. Macias-Medina, 268 P.3d 1201

Macias-Medina was charged with two counts of rape and pled guilty to an off-grid version of aggravated indecent liberties with a child under a plea agreement.
State promised not to oppose departure to the middle sentencing-grid number, concurrent sentences, and defense probation on the plea.
Before sentencing, Macias-Medina moved to withdraw his pleas, alleging coercion by his attorney and interpreter.
District court found competent representation, knowing and intelligent pleas, no dishonest information, and no coercion; denied withdrawal.
Defendant was sentenced to 59 months under the plea recommendations; he appealed the denial of withdrawal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused discretion denying withdrawal	Macias-Medina argues coercion and misrepresentation by counsel/interpreter	State asserts credibility favoring attorney/interpreter over defendant	No abuse; credibility and evidence support denial
Whether Edgar factors required withdrawal	Coercion and incompetence support good cause	Factors met are not satisfied; plea was knowingly made	Edgar factors not all satisfied; no good cause to withdraw
Standard of review for presentence withdrawal decisions	Standard should acknowledge good cause before sentencing	Defer to district court on credibility and factual findings	Court affirmatively defers; no error in deference

State v. Aguilar, 290 Kan. 506 (Kan. 2010) (three Edgar factors; flexibility in applying them)
State v. Edgar, 281 Kan. 30 (Kan. 2006) (origin of Edgar factors)
State v. Ward, 292 Kan. 541 (Kan. 2011) (definitions of abuse of discretion standard)
State v. Denmark-Wagner, 292 Kan. 870 (Kan. 2011) (pre-sentence withdrawal standard; discretion)
Wippel v. State, 203 Kan. 207 (Kan. 1969) (misleading information standard in plea context)