In Michigan, "A "nolo contendere" plea does not admit guilt, it merely communicates to the court that the criminal defendant does not wish to contest the state's accusations and will acquiesce in the imposition of punishment." "Lichon v American Universal Insurance Co.", 435 Mich 408, 417 (1990). A "nolo contendere" plea may be appropriate "where the defendant would not be able to supply a sufficient factual basis for a guilty plea because he or she was intoxicated on the night of the incident, where there is the possibility of future civil litigation resulting from the offense, or where a defendant cannot remember the events which led to his or her being charged with a crime". 1A Gillespie Michigan Criminal Law & Procedure, § 16:15.