Sanchez-Martinez v. People
Annotate this CaseThe district court reversed the county court’s order to vacate Petitioner Nicanor Sanchez-Martinez’s guilty plea to third degree assault as “unknowing, involuntary and unintelligent.” Petitioner appeared pro se before the county court and pleaded guilty. He was sentenced to probation, and required to complete counseling sessions. Petitioner successfully complied with the terms of his probation, and subsequently the court terminated his sentence. One month following the termination, Petitioner filed a motion with the court that his sentence be set aside in light of new evidence that allegedly negated his guilt. At the hearing, the prosecution elicited testimony from Petitioner that he could not read or write Spanish or English, and was never informed of the constitutional rights he waived by pleading guilty. As a result, the magistrate expressed concern that Petitioner knowingly and voluntarily pleaded guilty. The magistrate informed both parties that he would set the plea aside as unconstitutional. The prosecution then appealed the magistrate’s decision to the district court. The district court reversed the county court, holding that the county court improperly addressed the constitutionality of Petitioner’s plea. The Supreme Court determined that the county court acted within its discretion and found the lower court’s conclusion was supported by the record. The Court reversed the district court’s decision and reinstated the county court’s judgment vacating Petitioner’s guilty plea.
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