State v. Haskins

Citations

• 2026 ND 23

Syllabus

Rule 11, N.D.R.Crim.P., does not require courts to specifically address a defendant's age, education, mental capacity, background, or experience during the plea colloquy. Courts have no duty under Rule 11 to inquire about or rule out potential affirmative defenses before accepting a guilty plea. A guilty plea generally waives all non-jurisdictional claims and defenses, including constitutional, procedural, and statutory defenses. Rule 11(b)(3) requires the court to determine a factual basis exists before entering judgment on a guilty plea. The factual basis must satisfy all elements of the charged crime and be sufficiently precise and specific on the record. Even when a Rule 11 violation constitutes obvious error, the defendant must demonstrate the error affected substantial rights. A sentence within the statutory range and the range contemplated in the plea agreement is generally not grossly disproportionate under Eighth Amendment analysis.