Robinson v. State

Supreme Court of Georgia · 2025 · Evidence

Evidenceguilty pleamotion to withdraw pleamanifest injusticeknowing and voluntary plearecord reviewcredibility determinationsde novo review

Facts

On the day trial was scheduled to begin, Robinson chose to plead guilty after the State agreed to withdraw its recidivist notice, dismiss several counts, and recommend a life sentence with the possibility of parole on one count. During the plea colloquy, Robinson stated under oath that he understood the court, understood what was happening, had reviewed the case with counsel, knew the rights he was waiving, knew the possible sentences, and was pleading freely and voluntarily. At the later motion hearing, plea counsel testified that Robinson had an apparent seizure-like episode about an hour before the plea, but that after orienting him for about an hour she believed he understood his rights and appeared coherent during the colloquy. Robinson testified that he did not remember the seizure or details of the plea proceeding and claimed he had not known he was pleading guilty.

Issue

Did the trial court err in denying Robinson's post-sentencing motion to withdraw his guilty plea on the ground that the plea was not knowing and voluntary because he allegedly suffered a seizure about an hour before the plea colloquy? Also, did the sentence on the vehicular homicide count need correction because that count was vacated by operation of law upon the felony murder conviction for the same death?

Rule

After sentencing, withdrawal of a guilty plea is within the trial court's discretion and is allowed only when necessary to correct a manifest injustice. A manifest injustice exists when, for example, a guilty plea was entered involuntarily or without an understanding of the nature of the charges. When a defendant challenges a plea as not knowing and voluntary, the State must show from the record that the defendant understood the plea, the nature of the charges, and the constitutional rights being relinquished; on appeal, factual findings are accepted unless clearly erroneous, credibility determinations are deferred to, and the ultimate conclusion is reviewed de novo.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Macon, Georgia, Devin Cole pleaded guilty to aggravated assault after the prosecutor agreed to dismiss two additional counts. During the plea colloquy, Devin said he understood the charge, the sentencing range, and the rights he was waiving, and that he was pleading voluntarily. Two months after sentencing, Devin moved to withdraw the plea, arguing only that he had changed his mind and now wanted a trial.

How should the trial court rule?

Explanation. After sentencing, withdrawal of a guilty plea is within the trial court’s discretion and is permitted only when necessary to correct a manifest injustice. A mere change of heart does not establish manifest injustice. The majority opinion explains that post-sentencing withdrawal is not available simply because the defendant regrets the bargain; the relevant question is whether the plea was involuntary or entered without understanding.