People v. Ingram

In People v. Ingram, 439 Mich 288, 300; 484 NW2d 241 (1992), the Supreme Court of Michigan "the concerns involved in collateral attacks of guilty plea procedures are quite different than those on direct appeal and implicate considerations of finality and administrative consequences." Based on such considerations and the distinctions between a direct appeal and a collateral attack, the court held "that failure of a plea-taking court to adhere to the applicable plea-taking requirements during the plea proceeding does not provide a defendant the opportunity to challenge by collateral attack." Id. at 294-295. The only exception to the bar against collateral attacks is if the defendant did not "intelligently waive the right to counsel, including the right to court-appointed counsel if indigent." Ingram, supra at 295.