North Dakota v. Brame
Annotate this CaseCharles Brame pleaded guilty to two counts of sexual assault. On appeal, Brame sought to withdraw his guilty pleas because the district court failed to explicitly ask him whether he was entering his plea voluntarily or whether his plea resulted from force, threats, or promises. "A Rule 11 error does not automatically lead to reversal." The North Dakota Supreme Court concluded that a defendant who failed to first raise the alleged error at the district court must show a Rule 11 violation’s impact on substantial rights before the Court will undo a guilty plea. Because Brame did not show the alleged violation had an impact on his substantial rights, the Court affirmed the judgment.
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