Idaho v. SunseriAnnotate this Case
Nicholas Sunseri was arrested in 2016, charged by uniform citation with two misdemeanors: domestic violence committed in the presence of a child, and interfering with a 911 call. Sunseri was in custody when he made his first appearance before the magistrate court. The magistrate court advised Sunseri of his rights and the potential penalties associated with the charges he faced. The City Attorney’s Office had previously lodged with the magistrate court a document styled as “Waiver of Appearance,” in which it waived the right to be present and advised the magistrate court of its plea offer to Sunseri. Although Sunseri had not met with an attorney to discuss the offer, the magistrate court advised Sunseri of the terms of the State’s plea offer. Sunseri responded that he understood and accepted the offer. Sunseri then waived his right to counsel and entered a plea of guilty to domestic violence in the presence of a child. The magistrate court then entered a no contact order and released Sunseri on his own recognizance after Sunseri signed his acknowledgement of receipt of the no contact order. Three days later, the magistrate court entered an order scheduling sentencing. Thereafter, Sunseri consulted with an attorney and learned that his guilty plea would result in a loss of his right to possess firearms and ammunition by operation of 18 U.S.C. section 922(g)(9). More than six weeks prior to his scheduled sentencing date, Sunseri moved to withdraw his guilty plea. Sunseri appealed the district court's affirmance of the magistrate court's order denying his motion to withdraw the plea. The Idaho Supreme Court reversed, finding the district court failed to recognize the magistrate court had not proceeded to the second step of determining whether there was any other just reason for withdrawal of his guilty plea. The result was to conflate the “manifest injustice” standard, which requires the trial court to grant a motion to withdraw a guilty plea, with the “just cause” standard, which confers discretionary authority upon the trial court to permit a defendant to withdraw a guilty plea.