Bonga v. Minnesota
Annotate this CaseAppellant Dario Bonga pled guilty to first-degree premeditated murder less than one day after he confessed to killing Carlos San Miguel and attempted to kill himself while in custody awaiting trial. The district court accepted Appellant’s guilty plea, convicted him, and sentenced him to life in prison. Appellant filed a petition for post conviction relief in which he sought to withdraw his guilty plea, arguing that he was not competent to plead guilty. On appeal to the Supreme Court, Appellant argued that the district court did not give sufficient weight to evidence that suggested he was incompetent to plead when it sentenced him to life. Particularly, Appellant argued that the court should have ordered an examination and report on Appellant’s mental condition when it learned that Appellant attempted suicide the day before the hearing. The Supreme Court’s review of the record revealed that on several occasions Appellant was offered counsel, dismissed counsel, sought to speak with the prosecutors, and asked to represent himself at trial. The record would also reveal that the trial court asked Appellant multiple times, on the record, whether he understood the nature of the charges against him and whether Appellant understood the risk he ran by representing himself. The Court was satisfied that the trial court gave Appellant every opportunity to seek counsel and preserve his legal rights. Finding no error, the Supreme Court affirmed Appellant’s conviction and sentence.
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