Tag Archives: Norgaard

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

NORGAARD Plea of Guilty (Unable To Recall) (10-16) (Replaced by 15-16)

QUESTION: WHAT IS A NORGAARD PLEA OF GUILTY? A Norgaard Plea is a procedure that governs situations where a defendant wants to enter a plea of guilty (usually in order to take advantage of a plea agreement) but is unable to recall facts due to intoxication or amnesia. Unlike an Alford plea, in a Norgaard Plea, Defendant does not make a claim he is innocent.

CLICK ON LINK BELOW TO READ MORE (Replaced by 15-16)

Pendleton10.16-NORGAARD_Plea_of_Guilty