This opinion will be unpublished and may not be cited except as provided by Minn. Stat. § 480A.08, subd. 3 (1994). STATE OF MINNESOTA IN COURT OF APPEALS CX-95-2732 City of St. Paul, Respondent, vs. Two Hundred Sixteen and 05/100 Dollars ($216.05) in Various Denominations of United States Currency, 15 Slot Machines and 5 Video Poker Machines as Listed on Attached Exhibit A, Appellants. Filed August 13, 1996 Affirmed Huspeni, Judge Ramsey County District Court File No. C3-94-3772 Timothy E. Marx, St. Paul City Attorney, Lisa L. Veith, Assistant City Attorney, 550 City Hall and Courthouse, 15 W. Kellogg Blvd., St. Paul, MN 55102 (for respondent) Greg J. Rebeau, 411 N. Lexington Parkway, Suite G, St. Paul, MN 55104 (for appellants) Considered and decided by Huspeni, Presiding Judge, Toussaint, Chief Judge, and Randall, Judge. U N P U B L I S H E D O P I N I O N HUSPENI, Judge Gary Southward argues that the district court erred when it granted the City of St. Paul summary judgment in a civil forfeiture action because (1) there are material issues of fact as to whether he realized his actions were illegal, and (2) the prior denial of the City's summary judgment motion by a different judge renders this decision improper. We affirm. FACTS The St. Paul Police Department received a tip that Gary Southward was selling illegal gambling equipment. As part of its investigation, officers called Southward pretending to have an interest in purchasing a number of pinball machines. Shortly after this call, three undercover officers arrived at Southward's home and expressed an interest in buying three slot machines. At this point, discussions took place as to the price and conditions of sale for the slot machines. Southward was then informed that he was under arrest for the sale of gambling devices and the officers seized 23 slot machines and $216.05 in United States currency. Southward subsequently entered a not guilty plea to the sale of a gambling device in violation of Minn. Stat. § 609.76, subd. 1(5) (1992). Three months later, however, Southward changed his mind and entered an Alford plea to a gross misdemeanor violation. He was sentenced to two years of unsupervised probation and fined $300. The City commenced a civil forfeiture action against the items that were seized when Southward was arrested. The City also moved for summary judgment against the property, claiming no material facts existed and that, as a matter of law, it was entitled to these items. This initial motion was denied because the court determined that issues of material fact did exist as to whether Southward realized his actions were illegal. The matter was set for trial before a different judge who revisited the City's request for summary judgment and granted the motion. D E C I S I O N I. Summary judgment will be granted only when the pleadings, depositions, answers to the interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue of material fact and that either party is entitled, as a matter of law, to a judgment. Fabio v. Bellomo, 504 N.W.2d 758, 761 (Minn. 1993). On appeal, this court must view the evidence in the light most favorable to the party against whom judgment was granted. Id. Southward asserts that the decision to grant summary judgment was erroneous because material fact issues exist as to whether Southward knew his conduct was illegal. We find no merit in this argument. The relevant statute provides: Exceptions: Property may not be seized or forfeited under this section if the owner shows to the satisfaction of the court that the owner had no notice or knowledge or reason to believe that the property was used or intended to be used in violation of this section. Minn. Stat. § 609.762, subd. 5. (1992) (emphasis added). In general, a party who asserts an "innocent owner" defense has the burden of proving this defense, and must establish the absence of knowledge that the property in question was used in a criminal offense. United States v. 92 Buena Vista Ave., 507 U.S. 111, 129-30, 113 S. Ct. 1126, 1137-38 (1993). Even when the evidence is viewed in the light most favorable to Southward, the burden to establish the defense of lack of notice or knowledge is insurmountable in this case. Because Southward entered a plea to the underlying gambling offense, he cannot now claim in the civil forfeiture proceeding that he did not know his actions were illegal. Cf. State v. Thornson, 170 Minn. 349, 212 N.W. 591 (1927) (holding that a driver who pled guilty to the unlawful transportation of liquor is barred, in a subsequent civil forfeiture action against the automobile, from claiming that his actions were not illegal because he did not intend to sell the alcohol). Furthermore, by his plea Southward has waived the right to claim now that his property is exempt from forfeiture because he did not know that his actions were prohibited. Cf. Parke v. Raley, 506 U.S. 20, 113 S. Ct. 517, 522 (1992) (holding that a guilty plea abrogates the right to a jury trial, the right to confront one's accusers, and the privilege against self-incrimination); see also Walton v. State, 294 Minn. 512, 198 N.W.2d 286 (1972) (guilty plea waives right to protest the admissibility of confessions); State v. Johnson, 422 N.W.2d 14, 16 (Minn. App. 1988) (a guilty plea by a counseled defendant operates as a waiver of all non-jurisdictional defects arising prior to entry of the plea), review denied (Minn. May 16, 1988.) II. Southward argues that summary judgment was not proper in this case because an earlier judge had ruled against granting the City's motion. He contends that where reasonable persons might draw different conclusions from the evidence presented, summary judgment is not proper. We also find this argument to be without merit. Southward's plea of guilty to the sale of gambling devices bars him from arguing any element of that offense. Following Southward's conviction for a gambling violation, the City is entitled to institute a civil forfeiture proceeding against the property seized during the arrest. See Minn. Stat. § 609.762, subd. 4. (1992). We agree with the district court that in this case there are no material issues of fact about which reasonable people could disagree. Under these circumstances, the district court made a proper decision to grant the City's summary judgment motion. A district court has the authority to correct any error that occurred earlier in the proceedings. Appellate courts are "loath to interfere with a trial court ruling which appears, in effect, to correct an earlier error." Albert v. Paper Calmenson & Co., 515 N.W.2d 59, 65 (Minn. App. 1994), aff'd as modified, 524 N.W.2d 460 (Minn. 1994). Therefore, we conclude that the district court did not err by deciding to reconsider, and eventually to grant, the City's summary judgment motion in this case. Affirmed. In an Alford plea, the defendant need not admit guilt. However, before accepting an Alford plea, the court must find that the plea (1) is intelligently, knowingly, and voluntarily made; (2) is based on the court's interrogation; (3) is based on the court's analysis of the factual basis offered in support of the plea; and (4) results from the court's reasonable conclusion that the evidence would support a jury verdict of guilt. North Carolina v. Alford, 400 U.S. 25, 91 S.Ct. 160 (1970); see also State v. Goulette, 258 N.W.2d 758, 760 (Minn. 1977). In a civil forfeiture action following a criminal conviction, we can discern no basis upon which a conviction following a jury trial should be distinguished from a conviction following a guilty plea. Therefore, a conviction following an Alford plea should not be distinguished from these other convictions.