Idaho inmate seeks to overturn guilty plea, legal experts say chances are low

A year after pleading guilty to the murders of four University of Idaho students, Bryan Kohberger has filed a post-conviction motion to withdraw that plea. In a court filing, Kohberger alleges that his attorneys provided ineffective assistance, failed to discuss exculpatory evidence, and made false promises about prison conditions and privileges. He claims the plea was not entered voluntarily and was induced by “unkept promises” and threats from his lawyers.

Kohberger’s plea, entered in July 2023, avoided a death-penalty sentence and resulted in life imprisonment without parole. The plea agreement required him to affirm, via a nine-page questionnaire, that he was pleading freely, understood the charges, and waived his right to appeal. Legal scholars explain that while a waiver of appeal limits traditional appellate review, defendants can still pursue post-conviction relief on grounds such as ineffective counsel or coercion, though the burden of proof is high.

Idaho Rule of Criminal Procedure 33(c) permits withdrawal of a guilty plea before sentencing for “fair and just reason,” but after sentencing it is allowed only to correct a “manifest injustice.” To succeed, Kohberger must demonstrate that his plea was involuntary or that counsel’s performance was so deficient that it deprived him of a fair trial, requiring concrete, credible evidence. Experts note that his on-record admission of guilt and the thorough plea colloquy conducted by Judge Steven Hippler weigh heavily against his claim.

Law professor Samuel Newton said the standard for showing “manifest injustice” is stringent and that successful withdrawals in cases like this are “slim to none.” Legal analyst Joey Jackson added that Kohberger would need to present new, compelling evidence—such as DNA or cellphone data—that was unavailable at the time of his plea to have a viable chance of overturning the conviction.