NORGAARD PLEA OF GUILTY (Unable to Recall Facts) Three Steps to Making a Proper Record

Dear Colleagues:

Are you confident your Minnesota “unable-to-recall” guilty pleas would survive appellate review?

A Norgaard plea applies when a defendant wants to plead guilty (often for a plea bargain) but can’t recall the events due to intoxication or amnesia—and unlike an Alford plea, the defendant is not claiming innocence.

In this Martine Law Training Update, I break the procedure down into a practical three-step checklist and provide a ready-to-use in-court script that tracks the Norgaard Addendum (Rule 15, Appendix H)—so judges, prosecutors, and defense attorneys can make a complete record in real time.

👉 Click below for a print-ready copy of Training Update #25-12 (and keep the in-court script handy for your next plea hearing).
Martine Law Training Update #25-12