Notification Prior to Accepting a Guilty Plea

In State v. Calhoun, 96-0786 (La. 5/20/97), 694 So. 2d 909, the Supreme Court interpreted La. R.S. 15:543(A) as requiring a district court to advise a defendant of the notification requirements prior to accepting a guilty plea. 694 So. 2d at 913. The court further held that a district court's failure to timely notify a defendant of the registration requirements is a factor that can undercut the voluntary nature of a guilty plea. The Supreme Court cited other factors in support of its decision to allow the defendant to withdraw his guilty plea, and it said it was expressing no opinion as to whether the failure to timely notify a defendant of the registration requirements alone would require a district court to permit a guilty plea to be withdrawn. Calhoun, 694 So. 2d at 914 n.6.