Does Utah's thirty-day deadline for withdrawing guilty pleas violate constitutional rights? State v. Merrill Explained

In State v. Merrill, the Utah Supreme Court addressed whether Utah Code section 77-13-6(2)(b)’s thirty-day limitation for withdrawing guilty pleas creates an unconstitutional jurisdictional bar. This case provides important guidance for criminal defense practitioners about the strict time limits governing plea withdrawal motions and the constitutional parameters surrounding such deadlines.

Background and Facts

Scott Merrill shot and killed Charles Watterson, an Emery County employee operating a road grader, believing he was acting on a divine commandment. Merrill pleaded no contest to aggravated murder in exchange for dismissal of other charges and the State’s agreement not to seek the death penalty. During his plea colloquy, Merrill acknowledged he was taking Zoloft but stated the medication did not prevent him from entering a knowing and voluntary plea. More than thirty days after his plea, Merrill filed a motion to withdraw it, claiming his medication had caused religious delusions that affected his comprehension during the plea process.

Key Legal Issues

The court addressed two primary questions: whether Utah Code section 77-13-6(2)(b) creates a jurisdictional bar to withdrawing guilty pleas after thirty days, and whether this limitation violates constitutional provisions including open courts, separation of powers, due process, and equal protection guarantees.

Court’s Analysis and Holding

The Utah Supreme Court affirmed that the thirty-day limitation is indeed jurisdictional, building on prior decisions in State v. Abeyta, State v. Ostler, and State v. Reyes. The court distinguished plea withdrawal motions from habeas corpus petitions, noting that unlike the “great writ,” plea withdrawal rights lack constitutional protection and alternative remedies remain available through the Post-Conviction Relief Act. The court rejected all constitutional challenges, finding that the statute provides adequate procedural safeguards and treats similarly situated defendants uniformly.

Practice Implications

This decision establishes that Utah’s plea withdrawal deadline is strictly jurisdictional and cannot be waived or extended. Defense attorneys must file any motion to withdraw a guilty plea within thirty days of entry of final judgment or lose that avenue of relief entirely. However, defendants retain access to post-conviction remedies even after the deadline expires, providing an alternative mechanism to challenge invalid pleas.