Alanis v. State

In Alanis v. State, 583 N.W.2d 573 (Minn. 1998), the State argued "direct consequences are those which flow definitely, immediately, and automatically from the guilty plea, namely, the maximum sentence to be imposed and the amount of any fine; . . . any consequence that results from actions taken by other government agencies such as the INS are collateral; and deportation is a collateral consequence" of a guilty plea. The Minnesota Supreme Court found the State's argument persuasive, ruling: It makes sense that direct consequences are those which flow definitely, immediately, and automatically from the guilty plea--the maximum sentence and any fine to be imposed. Further, it makes sense that deportation is not a direct consequence of the guilty plea because deportation is neither definite, immediate, nor automatic. Before a resident alien such as Alanis can be deported, the INS must exercise its discretion to commence deportation proceedings and, prior to deportation, there are various administrative procedures which must be followed. We are satisfied from the record that Alanis, before pleading guilty, knew and understood the charges against him and his rights under the law as well as the direct consequences of making the plea, that being the maximum sentence and the amount of any fine to be imposed. Thus, we conclude that the postconviction court's decision that withdrawal of Alanis's guilty plea was not necessary to correct a manifest injustice was not error. (Alanis, 583 N.W.2d at 578-79.)