State v. Young, 71 So. 3d 565

Young was charged with second-degree kidnapping; forcible rape was added and later dismissed; he pleaded not guilty and then guilty to kidnapping as part of a plea agreement.
A Prieur hearing was held; trial court limited testimony and clarified admissible testimony; a sanity/competency hearing was later granted and held.
Young was found competent to proceed; defense moved to withdraw the guilty plea, which the trial court denied; sentencing was imposed with specified limitations.
The defense alleged the plea was involuntary due to panic and medical issues; psychologist reports conflicted on voluntariness and rationality of the plea.
The trial court conducted a thorough Boykin colloquy, but the appellate court found the need for an evidentiary hearing on involuntariness and remanded for that purpose.
The State argued the bill of information properly charged second-degree kidnapping; the court held the information was valid under RS 14:44.1 and that sufficiency challenges were waived absent a pre-trial motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the plea withdrawal denial an abuse of discretion?	Young's plea involuntary due to panic and coercive influences.	Plea was involuntary; evidentiary hearing required.	Yes; denial was an abuse; remanded for evidentiary hearing.
Did the trial court err in denying an evidentiary hearing on involuntariness?	Evidence from psychologists supports involuntariness; hearing necessary.	Colloquy and competency findings negate need for a hearing.	Abused discretion; evidentiary hearing required on withdrawal motion.
Did the bill of information properly state a crime under a valid statute?	Reading RS 14:44.1 with subparts supports second-degree kidnapping as charged.	Questioned sufficiency of the charging instrument and statutory interpretation.	Bill of information valid; sufficiency not reviewable absent pre-trial motion.
Was the bench's competency/ sanity hearing adequate, or did it require additional steps for withdrawal analysis?	Psychological evidence undermines voluntariness; hearing needed.	Competency findings were adequate; no extra hearing required.	Remand for evidentiary hearing on withdrawal; competency findings considered but not dispositive.

State v. Lewis, 421 So. 2d 224 (La. 1982) (recognizes standards for withdrawal of guilty pleas after sentencing)
State v. Blanchard, 786 So. 2d 701 (La. 2001) (colloquy and voluntariness in plea bargaining; factors for involuntariness)
State v. Johnson, 406 So. 2d 569 (La. 1981) (thorough colloquy; voluntariness of plea; evidentiary hearing considerations)
State v. Rhea, 876 So.2d 131 (La.App. 4 Cir. 2004) (assessments of counsel influence and plea bargains in withdrawal motions)
State v. Bennett, 345 So.2d 1129 (La. 1977) (Bennett criteria for competency to proceed and understanding proceedings)
State v. Silva, 699 So.2d 487 (La.App. 4th Cir. 1997) (articulates standard for mental capacity to stand trial)
State v. Calhoun, 694 So.2d 909 (La. 1997) (competency and voluntariness considerations in plea proceedings)