State v. Fretwell
State v. Fretwell, 2025 UT App 96 (per curiam)
Criminal
The Utah Court of Appeals held:
- The district court appropriately denied Defendant’s post-judgment motion to withdraw his guilty plea because although Rippey struck down a statutory requirement to file a motion to withdraw a guilty plea before sentencing to preserve a challenge to the plea on direct appeal, it did not more broadly affect the time to move to withdraw a guilty plea.
- Practice tip: No rule allows a district court to consider a post-judgment motion to withdraw a guilty plea.