State v. Hamilton
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In this case presided by the Supreme Court of North Dakota, the defendant, Michael Dean Hamilton, was charged with hindering law enforcement under N.D.C.C. § 12.1-08-03(1)(b) by providing transportation and money to an individual involved in an abduction crime in Virginia. Prior to the trial, Hamilton and the State reached a plea agreement, but the district court rejected it, citing insufficient factual basis for Hamilton's guilty plea. Instead, the district court accepted an open plea from Hamilton. On appeal, Hamilton argued that the district court had abused its discretion by rejecting the plea agreement and then accepting the open plea, despite both requiring a factual basis. He also claimed that the court had relied on impermissible sentencing factors, including information outside the record and inferences from the record.
In its decision, the Supreme Court of North Dakota held that Hamilton's claim regarding the rejection of the plea agreement was waived when he entered an open guilty plea knowingly, voluntarily, and intelligently. The court stated that after entering an open plea without conditions, a defendant could only challenge the voluntary and intelligent nature of the plea. Therefore, Hamilton could no longer challenge the non-jurisdictional defects of the district court's rejection of the plea agreement.
Regarding the sentencing factors, the Supreme Court found that the district court did not commit an obvious error when it considered information outside the record and relied on its personal knowledge about Amber alerts in deciding Hamilton's sentence. The court stated that Hamilton had not demonstrated that the factors considered by the court were a clear deviation from the applicable statutory provisions, case law, or rules of evidence. As a result, the judgment of the district court was affirmed.
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