Waltrip v. Commonwealth: Voluntariness of Alford Pleas, Group Plea Colloquies, and Counsel’s Role in Plea Withdrawal Motions

I. Introduction

The Supreme Court of Kentucky’s unpublished memorandum opinion in Randall Waltrip v. Commonwealth of Kentucky (No. 2024-SC-0555-MR, rendered Dec. 18, 2025) affirms a Hancock Circuit Court judgment following Randall Waltrip’s Alford guilty plea to first-degree rape. Though designated “Not To Be Published” under RAP 40(D) and thus non-precedential, the opinion provides a detailed application of Kentucky’s rules governing:

the voluntariness of guilty pleas, including Alford pleas,
the constitutional adequacy of a group plea colloquy,
the standard for withdrawing a guilty plea under RCr 8.10,
appellate “palpable error” review under RCr 10.26, and
ineffective assistance of counsel in the plea and plea-withdrawal context.

Waltrip, charged with multiple Class A sexual offenses against his three-year-old daughter, entered an Alford plea to one count of first-degree rape in exchange for dismissal of seven additional counts (rape, sodomy, and incest involving a victim under twelve). Before final sentencing, he moved to withdraw his plea, arguing that:

the plea was taken during a group colloquy that did not ensure his individual understanding,
he lacked medication and had low education, making him vulnerable to confusion, and
his trial counsel was ineffective, both in pushing him to plead and in otherwise failing to represent him adequately.

The trial court held an evidentiary hearing, rejected these arguments, and sentenced Waltrip pursuant to the plea agreement (20 years, 85% parole eligibility, lifetime sex offender registration, sex offender treatment). On appeal, the Supreme Court affirmed.

Although unpublished, this opinion is important for its concrete articulation of how Kentucky courts:

evaluate group plea colloquies under Boykin v. Alabama,
apply the “totality of the circumstances” test to voluntary Alford pleas,
assess ineffective assistance claims in the plea-and-withdrawal setting (particularly where counsel declines to file a withdrawal motion), and
treat a defendant’s subsequent assertions about confusion or coercion in light of sworn plea colloquy responses.

II. Summary of the Opinion

A. Procedural Posture and Outcome

Waltrip appealed “as a matter of right” under Ky. Const. § 110(2)(b), challenging the trial court’s denial of his presentence motion to withdraw his guilty plea. The Supreme Court of Kentucky:

Affirmed the Hancock Circuit Court’s judgment and sentence.

B. Core Holdings

Group Plea Colloquy: A group plea colloquy, though “not preferred,” does not render a plea involuntary per se. Under Rigdon v. Commonwealth, the key is whether each defendant:
- is represented by counsel,
- is not lost in so large a group that individual understanding becomes unlikely, and
- is addressed individually regarding rights, charges, implications of pleading guilty, and intent to plead.
The Court held that these conditions were met, and there was no (palpable) error in the colloquy.
Voluntariness of Plea: Under Boykin and Kentucky precedent (Edmonds, Rodriguez, Crawford, Kotas), the trial court’s finding that Waltrip’s plea was knowing, intelligent, and voluntary was supported by substantial evidence. His subsequent claims of confusion and coercion did not overcome the strong presumption of verity accorded to his sworn statements at the plea hearing.
Palpable Error Standard: Because the challenge to the group colloquy was not properly preserved, review proceeded under RCr 10.26 (palpable error). The Court found no error—let alone one “shocking or jurisprudentially intolerable”—and thus no basis for relief.
Ineffective Assistance of Counsel and Plea Voluntariness: Applying Bronk v. Commonwealth and related cases, the Court held:
- Counsel was not ineffective for advising Waltrip to accept a plea that dramatically reduced his exposure from a potential life sentence on eight Class A felonies.
- Waltrip failed to show specific investigative failures or trial-preparation omissions that fell below professional norms or caused prejudice; his arguments were speculative.
- Claims that he was “pressured” to plead were contradicted by his sworn colloquy statements that he had enough time, was not forced, and understood the plea.
Counsel’s Refusal to File Plea-Withdrawal Motion: Under Commonwealth v. Tigue and Marks v. Commonwealth, the decision to seek withdrawal of a guilty plea belongs to the defendant, and the defendant is entitled to assistance of counsel in making that request. However, due to conflict concerns, counsel who represented the defendant in entering the plea is often not the appropriate lawyer to handle the withdrawal request.
- Here, original counsel ethically declined to file the motion; the trial court permitted him to withdraw, appointed new counsel, and Waltrip ultimately retained private counsel who pursued the motion.
- The Supreme Court found no violation of Tigue and no prejudice to Waltrip from this sequence of representation.

III. Analysis of Precedents Cited

A. Alford Pleas and Their Nature

The opinion begins by describing the plea as an Alford plea. In North Carolina v. Alford, 400 U.S. 25 (1970), the U.S. Supreme Court held that:

a defendant may constitutionally plead guilty while maintaining innocence,
so long as the plea is voluntary, and
there is a strong factual basis for the plea, i.e., sufficient evidence such that a jury could convict.

The Kentucky court reiterates this definition (“a defendant pleads guilty and acknowledges the sufficiency of the evidence to convict but maintains his or her innocence”) and then applies the standard voluntariness analysis under Boykin and Kentucky cases. The opinion underscores:

Legal significance: An Alford plea is not subject to a fundamentally different voluntariness test; it still must be knowing, intelligent, and voluntary, but the critical inquiry is whether the defendant understands:

the nature of the charge,
the rights waived, and
the consequences of the plea,

while the factual basis is established by the evidence the Commonwealth can present, not by the defendant’s own narrative of guilt.

B. Boykin and the Constitutional Requirement of a Voluntary Plea

Boykin v. Alabama, 395 U.S. 238 (1969), is the foundational case on guilty pleas. It holds that a guilty plea is more than a confession; it is itself a conviction, and due process requires that:

the record affirmatively show that the plea is knowing, intelligent, and voluntary,
the defendant understands the rights waived (jury trial, confrontation, privilege against self-incrimination, etc.).

The Kentucky Supreme Court invokes Boykin to frame the inquiry and then looks to its own precedents: Edmonds v. Commonwealth, 189 S.W.3d 558 (Ky. 2006), Rodriguez v. Commonwealth, 87 S.W.3d 8 (Ky. 2002), Commonwealth v. Crawford, 789 S.W.2d 779 (Ky. 1990), and Kotas v. Commonwealth, 565 S.W.2d 445 (Ky. 1978).

These cases collectively establish in Kentucky that:

The voluntariness of a plea is determined by the totality of the circumstances, not rigid formulas.
A guilty plea is involuntary if the defendant:
- lacked full awareness of the direct consequences, or
- relied on misrepresentations by the court or prosecution.
A guilty plea is intelligent if the defendant:
- was advised by competent counsel about consequences and rights waived,
- was informed of the nature of the charge, and
- was competent at the time of entering the plea.

Crawford is particularly important here: it holds that voluntariness can be established when the defendant:

signs a written waiver of rights,
acknowledges the signature, and
acknowledges understanding the rights waived.

The Waltrip court expressly relies on Crawford and Kotas for the proposition that there is no “magic incantation” required: what matters is the substantive record of understanding and choice.

C. Group Plea Colloquies: Rigdon and State v. Neal

The central procedural concern in Waltrip’s appeal is the use of a group plea colloquy. The Court cites:

Rigdon v. Commonwealth, 144 S.W.3d 283 (Ky. App. 2004), which addresses multi-defendant plea hearings.
State v. Neal, 810 S.W.2d 131 (Tenn. 1991), cited in Rigdon as persuasive authority.

From Rigdon (building on Neal), the rule is:

Group plea colloquies are not preferred, but are not constitutionally invalid per se.
Minimal safeguards must be observed:
- each defendant must have counsel,
- the number of defendants cannot be so large as to make individual understanding unlikely, and
- each defendant must be individually addressed about:
  - rights,
  - the charges,
  - implications of a guilty plea, and
  - intent to plead.

Applying this framework, the Waltrip court found:

Only five defendants were present—far from an unmanageable number.
Each had counsel, and Waltrip’s counsel stood directly behind him during the entirety of the proceeding.
The trial court addressed each defendant, including Waltrip, individually:
- confirming ability to read and understand the plea forms,
- inquiring about mental health and medication,
- confirming understanding of rights waived and terms of the plea,
- eliciting Waltrip’s express assent that he did not need more time with counsel.

This is an important clarification: while courts discourage group colloquies, they are permissible if they do not undermine individualized understanding and voluntariness.

D. Palpable Error Review: RCr 10.26, Brewer, and Martin

Because Waltrip did not properly preserve his group-colloquy challenge by citation to the record as required by RAP 32(A)(4), review proceeded under Kentucky’s “palpable error” rule, RCr 10.26 (misprinted in the opinion as “RCr410.26”).

RCr 10.26 allows consideration of unpreserved error where:

the error affects substantial rights, and
“manifest injustice” has resulted.

The Court relies on:

Brewer v. Commonwealth, 206 S.W.3d 343 (Ky. 2006) – defining “palpable” error as “easily perceptible, plain, obvious, and readily noticeable.”
Martin v. Commonwealth, 207 S.W.3d 1 (Ky. 2006) – manifest injustice is shown by:
- a probability of a different result, or
- an error so fundamental as to threaten due process.

The Court further quotes Martin’s formulation that palpable error exists when the defect is “shocking or jurisprudentially intolerable.”

In Waltrip, the Court:

found no defect in the plea process, so it never reached the question of whether any such defect rose to the “shocking” level; and
emphasized that the record affirmatively showed understanding and voluntariness, refuting any claim of manifest injustice.

E. Ineffective Assistance in the Plea Context: Bronk, Rigdon, Campbell

The Court’s analysis of ineffective assistance centers on:

Bronk v. Commonwealth, 58 S.W.3d 482 (Ky. 2001), which adapts the Strickland test to guilty pleas,
Rigdon again, and
Commonwealth v. Campbell, 415 S.W.2d 614 (Ky. 1967).

Under Bronk, a defendant must prove:

Deficient performance – counsel’s errors were so serious that counsel was not functioning as the “counsel” guaranteed by the Sixth Amendment; and
Prejudice in the plea context – that, but for counsel’s errors, there is a reasonable probability the defendant would not have pled guilty and would have insisted on going to trial.

Campbell provides a key principle for plea advice:

Counsel is not constitutionally ineffective merely for advising a client to plead guilty in order to receive a lesser sentence.

Superimposing these standards, the Court concludes:

Given Waltrip’s exposure to a potential life sentence on eight Class A felonies and his damaging police statements, counsel’s advice to accept a 20-year deal was objectively reasonable.
Waltrip failed to articulate specific investigative steps that should have been taken, what they would have revealed, and how they would have changed his decision to plead.
His speculation is insufficient; as Rigdon notes, ineffective-assistance claims cannot rest on mere conjecture.

F. Weight of Sworn Statements: Blackledge v. Allison

The Court relies heavily on the U.S. Supreme Court’s decision in Blackledge v. Allison, 431 U.S. 63 (1977), for the principle that:

“Solemn declarations in open court carry a strong presumption of verity.”

And that post hoc, conclusory allegations that contradict the record may be summarily rejected, especially where they lack specific factual support or are “wholly incredible” in light of the record.

Applied here, Waltrip’s sworn plea-colloquy assertions that:

he understood the plea,
had sufficient time with counsel,
had not been forced or coerced,
was not under the influence of any impairing condition, and
was satisfied with counsel,

are given heavy weight. His later testimony at the evidentiary hearing, to the contrary, is viewed as “self-serving” and insufficient to overcome that presumption.

G. Counsel’s Role in Plea Withdrawal: Tigue and Marks

The opinion addresses a nuanced point: when a defendant wants to withdraw a guilty plea, what are counsel’s obligations? The Court cites:

Commonwealth v. Tigue, 459 S.W.3d 372 (Ky. 2015), and
Marks v. Commonwealth, 555 S.W.3d 462 (Ky. App. 2018).

From Tigue:

The decision to seek withdrawal of a guilty plea belongs to the defendant, not counsel.
If the defendant desires to withdraw the plea before judgment, he is entitled to assistance of counsel in making that request.

From Marks:

There is an inherent risk of conflict of interest when the same counsel who advised the plea is asked to litigate its withdrawal (often by alleging their own ineffectiveness).
Courts must be wary of allowing original counsel to represent the defendant at the withdrawal stage.

In Waltrip, original counsel:

expressed ethical concerns about filing a motion to withdraw the plea he had helped negotiate and advise,
was permitted to withdraw by the trial court, which then appointed a public defender,
after which Waltrip retained private counsel who filed the withdrawal motion and represented him at the evidentiary hearing.

The Supreme Court therefore found:

no violation of Tigue’s requirement of counsel’s assistance in seeking withdrawal, since Waltrip ultimately had fully independent counsel during the withdrawal process, and
no prejudice arising from original counsel’s refusal to personally file the motion.

IV. The Court’s Legal Reasoning in Detail

A. Preservation, RAP 32(A)(4), and Palpable Error

Waltrip claimed that the group plea colloquy inadequately ensured his individual understanding. However, the Court first examined whether this issue was preserved.

Under RAP 32(A)(4), an appellate brief’s preservation statement must:

cite how the issue was raised in the trial court, and
specifically reference where in the record it was raised.

While Waltrip’s motion to withdraw mentioned the group colloquy, the “crux” of his argument below focused on ineffective assistance of counsel and voluntariness, not the structure of the colloquy itself. The Court thus held the colloquy-based challenge unpreserved.

Nonetheless, at Waltrip’s request, the Court conducted palpable-error review under RCr 10.26. It concluded:

There was no obvious, plain defect in the colloquy procedure.
The record showed individualized questioning and affirmations from Waltrip.
Accordingly, there was no “manifest injustice,” and thus no palpable error.

B. Adequacy of the Group Plea Colloquy

The Court closely examined the plea hearing transcript, noting that:

Waltrip was one of five defendants in unrelated cases.
He was individually questioned about:
- his education (“high school drop out”),
- ability to read and understand the plea documents (affirmative response),
- mental health history (denied mental illness or defect),
- whether his judgment was impaired (he said it was not),
- understanding of his plea terms and the rights waived,
- the nature of the charges and evidence against him,
- satisfaction with counsel and need for additional time (he said he was satisfied and did not need more time), and
- the fact that he did not have to plead guilty that day.

The Court also rejected the argument that counsel was functionally “unavailable” because he represented another defendant:

The record showed counsel was standing directly behind Waltrip throughout the hearing.
The trial court explicitly offered time to confer; Waltrip declined the need to do so.

Based on this, the Court found the Rigdon safeguards satisfied and no prejudice from the group format.

C. Voluntariness, Education Level, and Mental State

Waltrip argued that:

his limited education,
his lack of medication at the plea, and
his general mental state

combined with the group setting to create confusion and undermine voluntariness. The Court’s reasoning responded point by point:

Education: The judge confirmed Waltrip’s ability to read and understand the plea forms, despite being a “high school drop out.” Education level alone does not vitiate a plea when the record shows understanding.
Mental Condition: The court inquired specifically into mental health and impairment; Waltrip denied any mental illness and denied any impairment at the time.
Medication: While Waltrip later claimed he did not have his medication, at the plea hearing he affirmatively denied impairment and affirmed understanding; again, Blackledge’s presumption of verity applies.

Under the totality analysis, the appellate court deferred to the trial court’s credibility determinations, finding substantial evidence that the plea was voluntary and intelligent.

D. Evaluating the Ineffective Assistance Claims

Waltrip raised multiple strands of ineffective assistance:

counsel’s recommendation to accept the plea,
alleged failure to investigate and prepare the case for trial,
alleged “pressure” to plead, and
counsel’s refusal to file a motion to withdraw the plea.

1. Advice to Plead Guilty

With eight Class A felony counts and potential life imprisonment at stake, the Commonwealth’s offer to dismiss seven counts in exchange for one 20-year sentence was a very substantial benefit. The Commonwealth also possessed:

Waltrip’s partially incriminating police statement, and
expert and medical evidence corroborating the child’s injuries.

Waltrip’s statement included admissions that:

he tickled his three-year-old daughter’s inner thighs to the point of bruising,
she said “ouch” and he “stopped,”
any sexual touching might have happened “by accident,”
a toy cucumber could have “slipped” and poked the child’s vagina, and
they were “both excited playing together,” with the toy used in a way he compared to a “playground.”

The Court found:

These statements are not a “steadfast denial” of wrongdoing; they are equivocal and in places incriminating.
Given this evidence and the sentencing exposure, it was not ineffective for counsel to advise a plea.

2. Alleged Lack of Investigation

Waltrip asserted that counsel was unprepared and failed to investigate, but produced no specifics at the evidentiary hearing about:

what additional evidence could have been found,
what witnesses would have said, or
how such evidence would have changed his decision to plead.

The record, conversely, showed that trial counsel:

requested and received discovery,
challenged the child victim’s competency to testify, and
opposed the Commonwealth’s motion to have the child testify outside Waltrip’s presence.

Without concrete evidence of undiscovered, favorable material that would have altered the plea calculus, the Court deemed this argument speculative and, under Rigdon, insufficient to establish deficient performance or prejudice.

3. Alleged Pressure to Plead

Waltrip claimed he was “pressured” and “rushed” into the plea, contrary to his desires to go to trial. The Court pointed out that:

during the plea colloquy, he testified under oath that:
- he had enough time with his attorney,
- he understood he did not have to plead that day,
- no one had forced or threatened him, and
- he was making the decision freely and voluntarily.

Applying Blackledge, the Court held that subsequent contradictory testimony cannot overcome these solemn in-court statements without compelling supporting evidence, which was lacking.

4. Counsel’s Refusal to File the Withdrawal Motion

On the original sentencing date, Waltrip, acting pro se, filed a handwritten motion to withdraw his plea. Trial counsel:

stated on the record that he did not believe he could ethically file such a motion, given his prior role,
was allowed to withdraw, after which Waltrip was provided substitute counsel, and
subsequently Waltrip retained private counsel who fully litigated the withdrawal motion.

The Court reasoned:

Under Tigue, the defendant—not counsel—decides whether to seek withdrawal; Waltrip clearly made that decision.
Under Marks, original counsel’s withdrawal avoided a conflict-of-interest risk; far from being deficient, it was consistent with ethical practice.
Because Waltrip had appointed and then retained counsel to handle the motion and evidentiary hearing, there was no violation of his right to counsel or prejudice from the initial refusal.

E. Standard of Review and Deference to Trial Court

Citing Edmonds and Rodriguez, the Court emphasizes:

If the trial court finds a guilty plea voluntary under the totality of the circumstances, that finding will be reviewed for clear error, i.e., whether it is supported by substantial evidence.
The trial court also has a front-row seat to assess the defendant’s demeanor and credibility at both the plea colloquy and later evidentiary hearing.

The Court found substantial evidence supporting voluntariness, including:

Waltrip’s written and oral waivers,
his acknowledgments of understanding and lack of coercion,
his affirmation of satisfaction with counsel, and
his acknowledgement that he was entering an Alford plea because the Commonwealth had sufficient evidence to convict him beyond a reasonable doubt.

As a result, the denial of the motion to withdraw was not clearly erroneous.

V. Clarifying Complex Legal Concepts

A. Alford Plea

An Alford plea is a type of guilty plea where the defendant:

does not admit actual guilt, but
acknowledges that the prosecution has sufficient evidence that a jury could reasonably convict beyond a reasonable doubt.

It allows a defendant to accept a conviction—and often a negotiated sentence—without making a factual confession, provided the plea is voluntary and there is a strong evidentiary basis.

B. Palpable Error and Manifest Injustice

Under RCr 10.26:

Palpable error means a clear, obvious error that affects substantial rights.
Manifest injustice means that the error probably changed the outcome, or is so fundamental that it undermines the fairness and integrity of the proceeding.

This is a narrow, exceptional remedy used only when normal preservation rules have not been followed and the error is egregious.

C. RCr 8.10 – Withdrawal of Guilty Pleas

RCr 8.10 allows a defendant to seek to withdraw a guilty plea “at any time before judgment”. Generally:

The decision to grant withdrawal lies in the trial court’s discretion.
However, if the plea was involuntary, the court must allow withdrawal.

If the defendant alleges involuntariness, they are entitled to an evidentiary hearing, as occurred in Waltrip’s case.

D. Ineffective Assistance of Counsel in the Plea Context

Ineffective assistance is assessed under a two-pronged test (derived from Strickland v. Washington, adapted by Bronk):

Deficient performance: Counsel’s actions were outside the range of reasonable professional assistance.
Prejudice: In plea cases, the defendant must show that, but for counsel’s errors, he would have rejected the plea and insisted on trial.

Speculation about what “might have” been done is not enough; the defendant must identify specific deficiencies and specific ways they would likely have altered the plea decision.

E. Class A Felonies and Sentencing Exposure

In Kentucky, a Class A felony, such as first-degree rape of a child under twelve, carries:

a severe range of punishment, typically including the possibility of a very long term of years or life imprisonment.

This context is vital to evaluating counsel’s advice to accept a plea that caps exposure at a fixed term, here 20 years with 85% parole eligibility.

F. Presumption of Verity for Plea Colloquy Statements

Courts treat a defendant’s sworn in-court answers at a plea hearing as highly reliable. This:

protects the finality of pleas, and
prevents defendants from easily undoing pleas by later claiming confusion or coercion without evidence.

To overcome this presumption, a defendant would need strong, specific, credible evidence that the colloquy did not reflect their actual understanding or circumstances.

VI. Potential Impact and Broader Significance

Although unpublished and non-binding under RAP 40(D), Waltrip is likely to be cited (where no published case is directly on point) because it:

A. Clarifies Treatment of Group Plea Colloquies

The opinion reinforces and applies Rigdon, providing a practical example of a group colloquy that passes constitutional muster:

limited number of defendants (here, five),
individualized questioning as to rights, understanding, and voluntariness,
clear presence and accessibility of counsel, and
case-specific focus (e.g., Alford plea, sentencing terms, lifetime registration).

Trial courts conducting multi-defendant plea sessions can look to this opinion as a blueprint for structuring the hearing and creating a robust record.

B. Emphasizes the Strength of Sworn Colloquy Statements

The decision underscores that:

a defendant’s later claims of misunderstanding, pressure, or confusion face an uphill battle when contradicted by the plea colloquy, and
courts will give substantial deference to the trial court’s credibility assessments.

Practically, this encourages thorough, careful plea colloquies and written waivers, as those records will often be dispositive in subsequent challenges.

C. Frames Counsel’s Duties in Plea and Plea-Withdrawal Contexts

Waltrip, read together with Tigue and Marks, clarifies that:

counsel may ethically advise a plea—especially where exposure is extreme and evidence is strong—without being deemed ineffective,
original plea counsel may decline to file a withdrawal motion when doing so would raise a conflict-of-interest concern, provided the defendant is given substitute counsel, and
the defendant’s right is to have counsel assist in presenting the withdrawal motion—not to force original counsel to disavow their own prior advice.

D. Illustrates Application of Palpable Error Standard to Plea Proceedings

By treating the group-colloquy challenge as unpreserved and applying RCr 10.26, the Court shows how:

appellate courts will be reluctant to find “shocking” or “jurisprudentially intolerable” error in a plea proceeding when the record affirmatively demonstrates understanding and voluntariness, and
defense counsel must carefully preserve structural objections at the trial level if they hope to obtain meaningful review later.

E. Contextualizes Alford Pleas in Child-Sex-Offense Prosecutions

Although not unique to this opinion, the context is important: child sex offenses often involve:

highly sensitive testimony,
expert medical evidence, and
enormous sentencing exposure.

Alford pleas can be particularly attractive to defendants who wish to maintain some denial of intent while avoiding trial risks. This opinion confirms that:

courts will focus on the evidentiary basis and the voluntariness of the decision, not on whether the defendant personally utters a detailed confession, and
defendants cannot easily retract an Alford plea later by recasting ambiguous or partial denials as complete innocence.

VII. Conclusion

The Supreme Court of Kentucky’s unpublished decision in Waltrip v. Commonwealth affirms a trial court’s denial of a presentence motion to withdraw an Alford plea to first-degree rape. Applying Boykin, Edmonds, Rodriguez, Rigdon, Bronk, Blackledge, Tigue, and Marks, the Court:

upheld the use of a carefully structured group plea colloquy,
found the plea voluntary and intelligent in light of the totality of the circumstances,
rejected ineffective assistance claims as speculative or contradicted by the record, and
approved the ethical handling of counsel’s withdrawal when a plea-withdrawal motion created a potential conflict.

Substantively, the opinion reinforces core principles:

a valid guilty plea—Alford or otherwise—rests on a thorough colloquy and a clear record of understanding,
subsequent attempts to recant must overcome the strong presumption of verity attached to sworn in-court statements,
ineffective assistance in the plea context demands concrete, non-speculative proof of both deficient performance and prejudice, and
defendants are entitled to, and should receive, conflict-free counsel when seeking to withdraw a plea before judgment.

While non-precedential, Waltrip will likely serve as a persuasive reference point in Kentucky for trial judges, prosecutors, and defense counsel encountering:

group plea hearings,
Alford pleas in high-stakes sex offense cases, and
post-plea claims of involuntariness or ineffective assistance.

Its core message is that careful on-the-record inquiry at the time of the plea—combined with ethically managed representation—remains the best safeguard against later collateral attacks on guilty pleas.