State v. Olson, 816 N.W.2d 830

Olson pleaded guilty to grand theft and aggravated eluding in a plea agreement with habitual-offender admission.
A separate Information charged Olson with additional grand theft; the State later dismissed other charges in the two files.
Olson moved to withdraw his guilty pleas; the circuit court denied, sentencing him to 15 years (grand theft 10-15? actually 15) and 2 years (consecutive) for the eluding charge, plus 10 years for the separate grand theft (consecutive).
Olson testified at withdrawal hearing that ADHD, medication issues, and father pressure affected his pleas; the court found his testimony not credible.
The court conducted multiple rights advisements and evaluated the factual basis for each plea, including a Part II habitual-offender admission, and found them knowingly and voluntarily made.
Olson appealed on two grounds: error in denying withdrawal and Eighth Amendment/cruel-and-unusual-punishment challenge; the Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court abused its discretion in denying withdrawal of guilty pleas	Olson	Olson	No abuse; denial affirmed
Whether Olson's sentences were grossly disproportionate under the Eighth Amendment	Olson	Olson	Not grossly disproportionate; sentences affirmed

State v. Wahle, 521 N.W.2d 134 (S.D. 1994) (liberal standard for pre-sentence withdrawal of a guilty plea)
State v. Grosh, 387 N.W.2d 503 (S.D. 1986) (withdrawal of plea before sentencing, not automatic rights)
State v. Engelmann, 541 N.W.2d 96 (S.D. 1995) (standard for evaluating withdrawal motions)
State v. Thielsen, 2004 S.D. 17 (S.D. 2004) (pre-sentence withdrawal requires factual showing; abuse of discretion near standard)
State v. Nachtigall, 741 N.W.2d 216 (S.D. 2007) (requires factual basis for plea; charges clearly stated)
State v. Beckley, 742 N.W.2d 841 (S.D. 2007) (knowingly and voluntarily entered plea; totality of circumstances)
State v. Goodwin, 681 N.W.2d 847 (S.D. 2004) (factors in totality-of-circumstances analysis for knowing voluntariness)
Monette v. Weber, 771 N.W.2d 920 (S.D. 2009) (reaffirmed Boykin rights waiver standard in SD)
State v. Schultz, 409 N.W.2d 655 (S.D. 1987) (scope of factual basis for guilty plea)
State v. Goodwin, 681 N.W.2d 847 (S.D. 2004) (relevance to voluntariness analysis)