Can defendants withdraw guilty pleas based on claims they couldn't read plea documents? State v. Collins Explained

The Utah Court of Appeals addressed whether a defendant can withdraw a guilty plea based on claims of inability to read plea documents in State v. Collins, 2015 UT App 214. The decision reinforces the importance of thorough rule 11 colloquies and demonstrates the high burden defendants face when seeking to withdraw guilty pleas.

Background and Facts

Collins was arrested on an outstanding warrant and for providing false information to police. Upon arrival at jail, he confessed to having heroin and later agreed to plead guilty to possession of a controlled substance in a drug-free zone. During the plea hearing, Collins affirmed he could read and understand English, had read the plea affidavit, understood his constitutional rights, and was entering the plea voluntarily. His counsel confirmed she had read the affidavit to him. Collins later moved to withdraw his plea, claiming he lacked his glasses, could not read the affidavit, and was misled by counsel about sentencing recommendations.

Key Legal Issues

The court addressed two issues: (1) whether the district court properly accepted Collins’ guilty plea under rule 11 requirements, and (2) whether the court abused its discretion in denying the plea withdrawal motion. Under Utah Code section 77-13-6, pleas may only be withdrawn upon showing they were not knowingly and voluntarily made.

Court’s Analysis and Holding

The Court of Appeals affirmed both rulings. Regarding plea acceptance, the court found Collins’ claim that he could not read the affidavit insufficient because: (1) his counsel read it to him, (2) he affirmed understanding its contents during the colloquy, and (3) he confirmed everything was true and correct. For the withdrawal motion, the court held that Collins failed to meet his burden of proving lack of understanding, noting his testimony only showed post-plea confusion about details, not contemporaneous misunderstanding of charges or constitutional rights.

Practice Implications

This decision emphasizes that thorough rule 11 compliance protects plea acceptance from later challenges. Courts may rely on defendants’ contemporaneous affirmations of understanding during properly conducted colloquies. Practitioners should ensure clients genuinely understand plea consequences and document any accommodations made for reading difficulties or other limitations during plea proceedings.