Barrow v. State
Annotate this CaseAppellant pleaded guilty to one count of third-degree sale of a narcotic drug and was sentenced to fifteen months’ imprisonment. Appellant later sought postconviction relief seeking to withdraw his guilty plea for lack of an adequate factual basis. Specifically, Appellant argued that because the factual basis for his plea was his admission that he gave cocaine to his wife to hide when police officers pulled over the car in which he was a passenger, his testimony at the plea hearing did not support his conviction for a “sale” because he did not admit that he relinquished possession of the controlled substance. The postconviction court denied Appellant’s petition, concluding that the statutory definition of “sell” requires only a physical transfer of the possession of the contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) the facts to which Defendant admitted during his guilty plea colloquy did not show that his conduct fell within the definition of “sell” in Minn. Stat. 152.01(15a)(1); and (2) because there was not a sufficient factual basis for Appellant’s plea, his motion to withdraw his guilty plea should be granted.
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