State v. Sanders
Annotate this CaseDefendant pleaded guilty to forgery. The circuit court accepted the plea after determining that a factual basis existed for the plea. The court sentenced Defendant without objection. Defendant appealed, arguing that the circuit court failed to obtain a factual basis that the offense occurred in South Dakota and that the adequacy of a factual basis for a plea is a jurisdictional issue. The Supreme Court affirmed, holding that an inadequate factual basis does not deprive a circuit court of its subject matter jurisdiction, and therefore, the circuit court had subject matter jurisdiction to adjudicate the case.
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