State of Tennessee v. Terry Phelps

Summary

The Tennessee Supreme Court reversed the trial court and Court of Criminal Appeals, holding that the trial court erred by failing to apply the proper multi‑factor analysis required under Tenn. R.Crim. P. 32(f) to determine a fair and just reason for pre‑sentence withdrawal of a guilty plea, and found that the defendant had established such a reason. The court granted the motion to withdraw the plea and remanded for further proceedings; the sentencing appeal was deemed moot.