The State charged petitioner with one count of second-degree intentional murder in violation under an aiding and abetting theory of criminal liability, one count of kidnapping, and one count of aggravated robbery. Petitioner was later indicted on charges of premeditated first-degree murder and first-degree intentional felony murder while committing a kidnapping. The mandatory penalty for a conviction of either premeditated murder or intentional felony murder while committing a kidnapping is life in prison without the possibility of release. Petitioner pleaded guilty to one count of first-degree felony murder during the commission of an aggravated robbery. The penalty for a conviction of first-degree felony murder while committing aggravated robbery is life in prison with the possibility of release after 30 years. The district court sentenced petitioner to life imprisonment with the possibility of release after 30 years. Petitioner subsequently filed a petition to withdraw his guilty plea under Minn. R. Crim. P. 15.05, subd. 1. The district court denied the petition.
The Supreme Court held that petitioner was entitled, under Minn. R. Crim. P. 15.05, subd. 1, to withdraw his guilty plea to correct a manifest injustice because the guilty plea record did not show that petitioner killed the victim while the defendant was committing the predicate crime of aggravated robbery and, accordingly, the factual basis of the guilty plea to felony murder was inaccurate. Reversed
Leslie J. Aldrich was publicly reprimanded.
Daniel B. McGuire was publicly reprimanded.
Kevin T. Duffy was conditionally reinstated to the practice of law and placed on probation for 2 years.