Quinn v. State

In Quinn v. State, 174 Vt. 562, 564, 816 A.2d 425, 428 (2002) (mem.), a post-conviction relief proceeding where prejudice is required, we invalidated a guilty plea as involuntary despite the defendant's statement in open court that his plea was voluntary, because there was evidence of coercion by his attorney. Other circumstances surrounding the plea failed to provide assurance the plea was voluntary; defendant had been depressed and had recently attempted suicide. In Quinn, the prejudice that we considered was prejudice to the voluntariness of the plea. Id. at 563, 816 A.2d at 426 (holding that a "court's finding of fundamental error in the acceptance of a guilty plea is sufficient to award post-conviction relief").