Idaho Supreme Court
State v. Goullette
June 6, 2024
Summary
The Idaho Supreme Court affirmed Goullette’s conviction after concluding that the record as a whole established that his Alford plea was knowing, voluntary, and intelligent, even though the district court did not independently recite the factual basis during the plea colloquy. The Court clarified that a strong factual basis is one way, but not the exclusive way, to evaluate an Alford plea. It also held that the district court was not required to revisit the plea at sentencing because the defense expert’s report disputed portions of the State’s evidence but did not raise an obvious doubt about Goullette’s guilt.