The People, Plaintiff and Respondent v. David Edward Palmer, Defendant and Appellant

Summary

The court held that a defendant may appeal a claim that the trial court failed to establish a factual basis for a felony no contest plea, even when defense counsel stipulated to the existence of such a basis. A bare stipulation may satisfy the statutory requirement without identifying facts or a supporting document when the plea colloquy shows that the defendant discussed the offense elements and defenses with counsel and was satisfied with counsel's advice. The court therefore affirmed the judgment because the trial court acted within its discretion in accepting the plea.