v. People

Summary

The court held that Brooks’s prior guilty plea to theft from a person was constitutionally valid and could support his habitual-criminal adjudication, despite the charging document and plea colloquy omitting the specific-intent element. Considering the relatively simple nature of the offense, Brooks’s prior experience with a theft charge, and competent counsel’s written assurance that she had explained the required mental state, the court found by a preponderance of the evidence that Brooks understood the charge. The court vacated the court of appeals’ opinion but affirmed its judgment on different grounds.