Background
Anthony Mattison was charged with multiple serious felonies including two counts of attempted second degree murder, attempted assault on officers, terroristic threats, firearm offenses, and methamphetamine possession across two counties. He entered a global plea agreement in which he pled no contest to two counts of attempted second degree murder in Adams County and to second degree murder and a firearm offense in Clay County. At the plea hearing, the trial court found that Mattison understood the nature of the charges, his rights, the factual basis for the pleas, and the consequences of his plea, and explicitly found the pleas were entered “knowingly, intelligently, and voluntarily.”
After the plea hearing, Mattison’s psychiatric medication was changed from Haldol and Lamictal to Haldol and Buspar. Following this medication change, Mattison filed a motion to withdraw his pleas, arguing that he was now able to think more clearly and had a “better understanding” of the plea agreement and its ramifications. At the hearing on the motion, Mattison submitted an affidavit but presented no medical testimony regarding the effects of the different medications. The trial court denied the motion to withdraw, and the district court then sentenced Mattison to 45 to 50 years’ incarceration on each count, ordered to run concurrently to one another but consecutively to sentences in the other county.
The Court’s Holding
The Nebraska Court of Appeals affirmed the trial court’s denial of the motion to withdraw pleas. The court held that Mattison failed to establish by clear and convincing evidence that his pleas were invalid. Although Mattison had been diagnosed with schizophrenia and was on psychiatric medications, the record showed he was not under the influence of any drugs when he entered his pleas and explicitly stated so to the court. The court emphasized that having a “better” understanding of a plea agreement after the fact does not mean the original understanding was inadequate, particularly when the defendant signed a written plea agreement affirming he “fully understood” it and was questioned by the judge about his understanding.
The court also affirmed the sentences as not excessive. The 45-to-50-year sentences were within the statutory maximum of 50 years for Class II felonies. The trial court properly considered all relevant sentencing factors, including Mattison’s age, mental health condition (schizophrenia), education, social background, extensive criminal history beginning at age 18, history of violence, and the nature of the offenses (shooting at police officers). The court noted that Mattison received substantial benefits through the plea agreement—most charges were dismissed and his potential prison time was significantly reduced compared to what he faced if convicted on all counts.
Key Takeaways
- Medication changes after a guilty or no-contest plea do not provide grounds for withdrawal unless they establish that the original plea was not knowing and voluntary—merely achieving a “better understanding” later is insufficient.
- Defendants have the burden to prove grounds for plea withdrawal by clear and convincing evidence; a simple affidavit without supporting medical testimony is inadequate.
- Trial courts have broad discretion in sentencing within statutory limits and need not reduce sentences merely because a defendant avoided trial or because other defendants received shorter sentences.
- A trial court’s findings at the plea hearing that a defendant understands his rights and pleas are entered knowingly and voluntarily are entitled to substantial weight on appeal.
Why It Matters
This decision establishes a high bar for defendants seeking to withdraw pleas based on mental health conditions or medication changes occurring after the plea hearing. It makes clear that courts will not second-guess the validity of a knowing and voluntary plea merely because a defendant later claims improved mental clarity or understanding. This is significant for defendants with serious mental health diagnoses who may experience fluctuations in medication or mental state, as the holding requires they provide concrete evidence—not just assertions—that their original pleas were involuntary or unknowing.
The decision also reinforces that appellate courts afford trial judges considerable discretion in sentencing within statutory limits and will not engage in comparative sentencing reviews across cases. Practitioners should note that plea agreements, even when they result in substantial prison time, are viewed favorably by courts as providing both the defendant and prosecution with certainty and efficiency, and this benefit factors into whether a sentence is deemed reasonable.