State v. Natoli

HOLOHAN, Justice.

We accepted jurisdiction of the state’s petition for special action to consider whether a defendant may collaterally attack the validity of a criminal conviction from a non-record court solely on the basis of a lack of record to support the finding that a factual basis existed for a plea of guilty. The issue is one of statewide importance because it affects the validity of most of the convictions based on a guilty plea entered in non-record courts.

The facts necessary for the resolution of this case are not in dispute. The defendant-real party in interest was charged in the…