☢ test - Í

plea. Alford, supra, 400 U.S. at 37; see also McKiernan v. State, 288 Ga. 140, 142–143(2) (702 S.E.2d 170) (2010) (affirming the denial of defendant’s motion to withdraw his guilty plea to felony murder despite the defendant’s assertion that the shooting with which he was charged was accidental, where the evidence showed he was motivated to plead guilty out of fear he might never be released from prison upon conviction, and in order to avoid putting his family through a trial). Normally, all that is required in order to meet constitutional muster is for the trial court to find that the record contains strong evidence of actual guilt, and for the accused to enter the plea voluntarily, knowingly, and understandingly of the rights he was waiving by entering the plea. Alford, supra.” 2. Record here established voluntariness of defendant’s plea. “The record shows appellant fully understood the facts and circumstances surrounding the plea. It shows that he made a decision to plead guilty to avoid the possibility of a life sentence without the possibility of parole upon conviction. See Bell v. State, [294 Ga. 5, 8(1) (749 S.E.2d 672) (2013)] (affirming the denial of appellant’s motion to withdraw his guilty plea where appellant entered the plea to avoid life without parole). He also made the decision in order to spare members of his family from the burden of testifying at trial. See McKiernan, supra, 288 Ga. at 143(2) (where one of the motivating factors for entering a guilty plea was to avoid putting his family through a trial). Accordingly, we reject appellant’s assertion that withdrawal of the pleas was required, in order to avoid a manifest injustice, as a result of insufficient evidence to support acceptance of his guilty plea. See Stinson v. State, 286 Ga. 499 (689 S.E.2d 323) (2010) (once a sentence has been entered, a guilty plea may only be withdrawn to correct a manifest injustice, such as denial of effective assistance of counsel or a showing that the plea was entered involuntarily or without an understanding of the nature of the charges).” Williams v. State, 334 Ga.App. 311, 779 S.E.2d 91 (November 2, 2015). State court properly denied motion to withdraw guilty pleas to simple battery and criminal trespass. Defendant challenges record “that he made his plea knowingly and voluntarily.” 1. “Plea form,” in which “Williams agreed that he understood the rights he was giving up in pleading guilty and that he understood the sentence the state was recommending … is not sufficient to establish the voluntariness of a guilty plea, [but] a plea form is evidence that can be used by the trial court in determining whether a plea was voluntary. See Pike v. State, 245 Ga.App. 518, 521(1) & n. 4, 538 S.E.2d 172 (2000).” 2. Trial counsel also testified at motion hearing that he had reviewed with Williams “the charges against him, had communicated the plea offer to him, had explained his right to choose whether to be tried by the court or by a jury, and had clarified what rights he was giving up in pleading guilty, including reviewing with him the rights listed on the plea form.” Contrary to defendant’s argument, trial counsel’s testimony “based on her general practice rather than a specific recollection of her interactions with Williams … can be used in establishing compliance with constitutional standards. See Barker v. Barrow, 290 Ga. 711, 714(9), 723 S.E.2d 905 (2012); Bazemore v. State, 273 Ga. 160, 162(1), 535 S.E.2d 760 (2000).” “‘Where, as here, the defendant has legal representation, a presumption arises that defense counsel routinely explained the nature of the offense in sufficient detail to give the accused notice of what he is being asked to admit.’ Wharton v. Anderson, 270 Ga. 22, 23(1), 504 S.E.2d 670 (1998).” 3. No verbatim transcript of factual basis required on plea in state court which didn’t “result[ ] in additional incarceration. See King v. State, 270 Ga. 367, 509 S.E.2d 32 (1998). The required contents of the record of a state court plea hearing are set out in Uniform State Court Rule 33.11: ‘[a] record of the proceedings at which a defendant enters a plea of guilty or nolo contendere shall be made and preserved. The record should include: (A) the inquiry into the voluntariness of the plea (as required in section 33.7); (B) the advice to the defendant (as required in section 33.8); [and] (C) the inquiry into the accuracy of the plea (as required in section 33.9)[.]’ The requirements of Uniform State Court Rule 33.11 may be satisfied by a combination of documentary or extrinsic sources, as long as they ‘provide reviewing courts with a record of the plea proceedings to determine if challenged pleas have been entered voluntarily and with proper understanding.’ King, 270 Ga. at 370(1), 509 S.E.2d 32 (citation omitted).” No indication here of the sentence imposed, but apparently not one that resulted in additional incarceration. Probation? 4. Lack of factual basis on record doesn’t automatically require withdrawal of plea. “ In order to successfully attack a guilty plea after sentencing, Williams must show that the trial court’s acceptance of his guilty plea caused him to suffer a manifest injustice. Ramsey v. State, 267 Ga.App. 452, 600 S.E.2d 399 (2004); State v. Evans 256 Ga. 332, 336(3), 454 S.E.2d 468 (1995). He has not done so. ‘[Williams] has argued only that the record contains an insufficient factual basis to support his plea, and, although he states that a manifest injustice occurred, he makes no contentions whatsoever supporting this statement.’ Ramsey, 267 Ga.App. at 453, 600 S.E.2d 399. The record does not support a finding that Williams suffered a manifest injustice.” Arrington v. State, 332 Ga.App. 481, 773 S.E.2d 430 (June 11, 2015). Following defendant’s guilty plea to armed robbery, trial court properly denied motion for out-of-time appeal. Defendant’s plea wasn’t made involuntary by failure to advise him of right to appeal where terms of negotiated plea included agreement not to appeal. “As part of his plea agreement, Arrington executed a waiver of his post-conviction rights, indicating that in exchange for the State's agreement not to pursue enhanced penalties, Arrington agreed to never challenge his guilty plea after the sentence was