Background
Corbin James Eystad pleaded guilty in 2021 to felony criminal possession of dangerous drugs under a plea agreement that waived several rights, including the right to require proof beyond a reasonable doubt and the right to appeal a finding of guilt. The District Court entered judgment on February 24, 2022, imposing a five-year suspended commitment to the Montana State Prison.
After Eystad violated probation, the court revoked the suspended sentence and resentenced him to four years in prison. In November 2024, Eystad moved to withdraw his guilty plea, arguing that body-camera footage showed an illegal stop and search and that appointed counsel was ineffective for failing to seek suppression of methamphetamine found in his backpack. The District Court denied the motion as untimely and later denied reconsideration.
The Court’s Holding
The Montana Supreme Court affirmed. Under § 46-16-105(2), MCA, Eystad had one year after his judgment became final to seek withdrawal of his plea. His judgment became final when the 60-day appeal period expired on April 25, 2022, making April 25, 2023, the deadline. His November 18, 2024 motion was more than eighteen months late.
The statutory exception for a late motion did not apply because Eystad did not claim that he was innocent or deny possessing the methamphetamine. His contention that the evidence was obtained unlawfully was a suppression argument, not a claim of innocence supported by evidence of a fundamental miscarriage of justice. The plea documents and record also did not show that his plea was involuntary or establish that counsel performed deficiently and that, but for counsel’s errors, Eystad would have gone to trial.
Key Takeaways
- A motion to withdraw a guilty plea filed more than one year after judgment becomes final requires a claim of innocence supported by evidence of a fundamental miscarriage of justice.
- An argument that incriminating evidence should have been suppressed does not, by itself, constitute the required claim of innocence.
- A defendant alleging ineffective assistance in the plea context must show both deficient performance and that, absent counsel’s error, the defendant would not have pleaded guilty.
Why It Matters
The decision underscores the strict time limit governing guilty-plea withdrawals in Montana and distinguishes actual innocence from claims that evidence was obtained unlawfully. Defendants seeking relief after the statutory deadline cannot invoke the miscarriage-of-justice exception solely through suppression or unsupported ineffective-assistance arguments.
The court issued the decision as a memorandum opinion under its internal operating rules, so it may not be cited and does not serve as precedent.