Medina v. People.
2023 CO 46. No. No. 21SC765. Criminal Procedure—Plea of Guilty—Constitutional Law—Due Process.
September 11, 2023
Medina pleaded guilty to felony menacing, even though he maintained his innocence of that charge pursuant to North Carolina v. Alford, 400 U.S. 25, 39 (1970). The trial court found that Medina’s plea was voluntary, knowing, and intelligent. But because Medina agreed to waive proof of a factual basis for the charge under Crim. P. 11(b)(6), the trial court did not make a finding as to whether strong evidence of Medina’s guilt existed.
The Supreme Court considered whether an Alford plea requires the trial court to make a finding of strong evidence of actual guilt to pass constitutional muster. The Court concluded that there is no such requirement. Rather, the Court held that a defendant may enter an Alford plea while nonetheless waiving the establishment of a factual basis for the charge under Crim. P. 11(b)(6), provided that the plea is voluntary, knowing, and intelligent. The Court therefore affirmed the court of appeals’ judgment, albeit on slightly different grounds.