State v. Mitchell

CourtIdaho Court of Appeals
DecidedMarch 18, 2026
Docket51824
StatusUnpublished

This text of State v. Mitchell (State v. Mitchell) is published on Counsel Stack Legal Research, covering Idaho Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Mitchell, (Idaho Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 51824

STATE OF IDAHO, ) ) Filed: March 18, 2026 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED CEDRIC SEBASTIAN MITCHELL, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) )

Appeal from the District Court of the Fifth Judicial District, State of Idaho, Twin Falls County. Hon. John K. Butler, Senior District Judge.

Order denying motion to withdraw guilty pleas, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Jason C. Pintler, Deputy Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Michael MacEgan, Deputy Attorney General, Boise, for respondent. ________________________________________________

GRATTON, Judge Cedric Sebastian Mitchell appeals from the district court’s order denying his motion to withdraw guilty pleas. Mitchell contends he demonstrated a just reason for withdrawal of his guilty pleas. We affirm. I. FACTUAL AND PROCEDURAL BACKGROUND In June 2019, Mitchell drove his vehicle into a busy intersection at seventy-seven miles per hour colliding into the back of a vehicle causing one occupant’s death and severely injuring the other occupant. Due to the force of the collision, two other vehicles were struck injuring the occupants inside. A grand jury indicted Mitchell on one count of first degree murder and five counts of aggravated battery. On April 28, 2023, after mediation and pursuant to Idaho Criminal Rule 11, Mitchell pled guilty to a reduced charge of second degree murder and one count of aggravated

1 battery, naming all injured victims. Mitchell and the State also agreed to a sentence of life in prison, although Mitchell would be able to argue for a lesser-fixed term with eligibility for parole. On June 20, 2023, Mitchell filed a motion to withdraw his guilty pleas. Mitchell’s counsel, Mr. Andersen, asserted that Mitchell was “not happy with the plea agreement,” “believe[d] he entered the agreement rashly,” “believe[d] he did not fully understand what he was doing in entering the Pleas,” and “believe[d] he is not guilty of the charges to which he pled.” In addition, Mitchell argued the withdrawal of his guilty pleas would not prejudice the State. The State objected, asserting that Mitchell knowingly and intelligently entered his guilty pleas with the assistance of his competent counsel. Andersen subsequently withdrew and Mitchell’s substitute counsel filed a brief and an affidavit in support of the motion describing Mitchell’s long history of mental illness. At the hearing on the motion, Mitchell testified that he had been diagnosed with schizophrenia and bipolar disorder as well as dyslexia. Mitchell stated that Andersen had never discussed his mental illness with him or how it could have served as a possible defense in his case. Further, Mitchell testified that he expressed concerns to Andersen after he entered his guilty pleas and did not feel like he fully understood what he agreed to. Andersen testified to discussions with Mitchell’s retained mental health expert and, in reviewing the psychiatric reports, he believed Mitchell’s mental illness would not serve as a defense, including as to the intent elements. Andersen testified that he discussed the elements of murder with Mitchell in detail. Andersen also testified that Mitchell did not communicate that he wanted to withdraw his guilty pleas for several weeks after entry of the pleas. The district court denied the motion in a written decision. The district court found Mitchell did not establish a just reason for withdrawal of his guilty pleas. In addition, the district court concluded the State would be prejudiced if it granted Mitchell’s motion to withdraw his guilty pleas. Mitchell appeals. II. STANDARD OF REVIEW Whether to grant a motion to withdraw a guilty plea lies in the discretion of the district court and such discretion should be liberally applied. State v. Freeman, 110 Idaho 117, 121, 714 P.2d 86, 90 (Ct. App. 1986). Appellate review of the denial of a motion to withdraw a plea is limited to determining whether the district court exercised sound judicial discretion as

2 distinguished from arbitrary action. Id. When a trial court’s discretionary decision is reviewed on appeal, the appellate court conducts a multi-tiered inquiry to determine whether the trial court: (1) correctly perceived the issue as one of discretion; (2) acted within the boundaries of such discretion; (3) acted consistently with any legal standards applicable to the specific choices before it; and (4) reached its decision by an exercise of reason. State v. Herrera, 164 Idaho 261, 270, 429 P.3d 149, 158 (2018). III. ANALYSIS Mitchell claims the district court erred in denying his motion to withdraw his guilty pleas because he demonstrated a just reason for the withdrawal. In addition, Mitchell argues the district court erred in determining the State would be substantially prejudiced if it granted Mitchell’s motion to withdraw his guilty pleas. The State contends the district court correctly denied the motion because Mitchell understood the terms of his plea agreement, his pleas were entered knowingly, intelligently, and voluntary, and his attorney competently represented Mitchell during the plea negotiations and discussed the terms of the plea agreement to ensure Mitchell’s understanding. The State also contends the district court correctly found the State would be prejudiced due to the extended timeline of the case and declining memories. If a guilty plea is constitutional, a party may move to withdraw a guilty plea prior to sentencing. Idaho Criminal Rule 33(c); State v. Hanslovan, 147 Idaho 530, 535, 211 P.3d 775, 780 (Ct. App. 2008). “Presentence withdrawal of a guilty plea is not an automatic right; the defendant has the burden of showing a ‘just reason’ exists to withdraw” a constitutionally adequate guilty plea. Hanslovan, 147 Idaho at 535, 211 P.3d at 780. The determination of whether an individual has demonstrated a just reason for the withdrawal of a guilty plea is based on a factual decision within the discretion of the district court. State v. Sunseri, 165 Idaho 9, 14, 437 P.3d 9, 14 (2018). The threshold “just reason” requirement is not an onerous burden. It is a reasonable requirement to be administered liberally and with due recognition of the serious consequences attending a guilty plea. State v. Baxter, 163 Idaho 231, 234, 409 P.3d 811, 814 (2018). The factors a trial court should consider when finding whether a defendant has just cause to withdraw a guilty plea include: (1) whether the defendant has credibly asserted his legal innocence; (2) the length of delay between the entry of the guilty plea and the filing of the motion; (3) whether the defendant had the assistance of competent counsel at the time

3 of the guilty plea; and (4) whether withdrawal of the plea will inconvenience the court and waste judicial resources. Sunseri, 165 Idaho at 14, 437 P.3d at 14. It is also within the discretion of the trial court to consider the good faith, credibility, and weight of the defendant’s assertions in support of his motion to withdraw his plea. Hanslovan, 147 Idaho at 537, 211 P.3d at 782. The defendant’s plea must be found constitutionally adequate before the just reason analysis is necessary. Id. at 535, 211 P.3d at 780. For a guilty plea to be constitutional, a defendant must enter it knowingly, intelligently, and voluntarily. State v. Rodriguez, 118 Idaho 957, 959, 801 P.2d 1308

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Related

State v. Hanslovan
211 P.3d 775 (Idaho Court of Appeals, 2008)
State v. Freeman
714 P.2d 86 (Idaho Court of Appeals, 1986)
State v. Dopp
861 P.2d 51 (Idaho Supreme Court, 1993)
State v. Rodriguez
801 P.2d 1308 (Idaho Court of Appeals, 1990)
State v. Mayer
84 P.3d 579 (Idaho Court of Appeals, 2004)
State v. Herrera
429 P.3d 149 (Idaho Supreme Court, 2018)
State v. Sunseri
437 P.3d 9 (Idaho Supreme Court, 2018)

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Bluebook (online)
State v. Mitchell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mitchell-idahoctapp-2026.