State v. Mutwale, 79 A.3d 850

Defendant Mutwale pleaded guilty in August 2012 to three misdemeanor domestic assault counts and a DUI.
At the Rule 11 change-of-plea hearing, the court warned that non-citizens pleading guilty could face deportation or denial of citizenship.
Defendant later sought to withdraw his plea, claiming ineffective assistance and immigration consequences were not properly explained.
The trial court denied the motion to withdraw, relying on the plea colloquy and Rule 11 compliance, and cited Rule 32(d).
The issue on appeal was whether the warning satisfied 13 V.S.A. § 6565(c)(1)-(2) and Rule 11(c)(7).
The Vermont Supreme Court affirmed, holding substantial compliance with Rule 11 was sufficient and the warning was adequate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the plea warning complied with 6565(c)(1).	Mutwale argues warning was insufficient.	Mutwale contends warning did not meet statutory language.	Warning substantially complied with Rule 11(c)(7).
Whether § 6565(c)(2) requires more than substantial compliance.	Strict compliance necessary for withdrawal.	Substantial compliance suffices; warning allowed withdrawal if later immigration impact shown.	Substantial compliance suffices; no automatic entitlement to withdrawal required.

State v. Riefenstahl, 172 Vt. 597 (2001) (requires only practical fairness, not verbatim recitation)
In re Hall, 143 Vt. 590 (1973) (discusses immigration consequences and cautioning responsibility)
Pilette, 160 Vt. 509 (1993) (court not required to predict future federal immigration outcomes)
State v. Setien, 173 Vt. 576 (2002) (defines direct consequences limited to court-imposed outcomes)
In re Moulton, 158 Vt. 580 (1992) (Rule 11 does not require forecasting all consequences)