State v. Lovell
Annotate this Case
Douglas Lovell pleaded guilty to aggravated murder. Lovell subsequently moved to withdraw his plea. The district court initially held that Lovell's motion was untimely, but the Supreme Court reversed and remanded for consideration of the merits of Lovell's motion. In district court, Lovell argued he had good cause to withdraw his plea because the trial court failed to strictly comply with Utah R. Crim. P. 11(e), which sets out the requirements for a lawful guilty plea. The district court held that the trial court complied with rule 11(e) and that, even if it did not, the error did not amount to good cause to allow Lovell to withdraw his plea because Lovell did not show that but for the error he would not have pled guilty. The Supreme Court reversed, holding (1) the trial court failed to strictly comply with rule 11(e) because the record did not contain statements that clearly and unequivocally informed Lovell of his right to be presumed innocent or his right to a public trial by an impartial jury, and (2) under the "good cause" standard, the trial court's error to strictly comply with rule 11(e) was an error that required reversal. Remanded.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.