State v. Williams, 366 P.3d 1101

In April 2008 Tarlene A. Williams pleaded no contest to first-degree murder in exchange for dismissal of other counts. She later sought to withdraw the plea.
Williams filed a presentence motion to withdraw; the district court denied it and the Kansas Supreme Court affirmed that she failed to show good cause. State v. Williams, 290 Kan. 1050, 236 P.3d 512 (2010).
She subsequently filed four K.S.A. 60-1507 motions (2011–2013) alleging ineffective assistance, intoxication, illiteracy, incompetence, and related claims; each was denied by the district court.
Williams filed two postsentence motions to withdraw her plea in 2013. The district court summarily denied the first as untimely under K.S.A. 2014 Supp. 22-3210(e)(1) and for lack of excusable neglect; she did not appeal that denial.
About a month later she filed an identical second postsentence motion (the motion at issue). The district court denied it as successive and on the basis of prior rulings; Williams appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of postsentence plea-withdrawal motion under K.S.A. 2014 Supp. 22-3210(e)(1)	Williams argues she should be allowed to withdraw her plea (reasons in her motion).	State contends the motion was filed more than 1 year after finality and thus untimely.	Court held motion untimely; the 1-year limit applied and expired for preexisting claims on April 16, 2010.
Excusable neglect tolling of the 1-year limit (K.S.A. 2014 Supp. 22-3210(e)(2))	Williams did not present grounds showing excusable neglect.	State contends no affirmative showing of excusable neglect was made.	Court held Williams made no affirmative showing of excusable neglect; district court’s prior ruling that she failed to show excusable neglect controlled.
Successive motion / res judicata	Williams admits the motion is successive but seeks relief based on the motion’s claims.	State contends res judicata bars relitigation because identical issues were previously decided.	Court held the motion is successive and barred by res judicata; prior adverse rulings preclude relitigation (State v. Kelly).
Standard of review for summary denial of plea-withdrawal motion	Williams challenges district court denial.	State relies on procedural posture and record.	Court applied de novo review for summary denials (per State v. Fritz) and concluded the record conclusively shows no relief is warranted.

State v. Williams, 290 Kan. 1050 (direct-appeal denial of presentence plea-withdrawal)
State v. Moses, 296 Kan. 1126 (application of 1-year time limit to preexisting claims)
State v. Fritz, 299 Kan. 153 (de novo review for summary denial of plea-withdrawal motions)
State v. Kelly, 291 Kan. 868 (res judicata bars successive plea-withdrawal relitigation)