State of Minnesota v. Paul James Steichen

Summary

The court held that a Norgaard guilty plea must satisfy the same strong-factual-basis requirement as an Alford plea. The State must at least describe the evidence it would present at trial so the district court can independently determine that there is a strong probability the defendant committed the offense. Because the plea hearing included only a general summary of the alleged conduct and no description of the State's evidence, the plea was invalid and the court affirmed the court of appeals.