Usually this is somebody who paid off the check at the Magistrate's office and didn't realize that it would put a criminal conviction on their record.  Here's the MAR language I use in that situation:  

1.                   At the time she handled the matter, she did not realize that she was pleading guilty to a criminal offense and that her action would result in a criminal conviction being entered against her.

2.                   One of the elements of Simple Worthless Check is that the accused writes the check "knowing at the time . . . that [the accused] has not sufficient funds on deposit in or credit with the bank or depository with which to pay the check or draft upon presentation."  N.C. Gen. Stat. 14-107(a).

3.                   The Defendant was not aware of the elements of the offense when she entered her guilty plea.  "A guilty plea operates as a waiver of important rights, and is valid only if done voluntarily, knowingly, and intelligently, 'with sufficient awareness of the relevant circumstances and likely consequences.'"  Bradshaw v. Stumpf, 545 U.S. 175, 183 (2005) (citation omitted).  A "guilty plea would indeed be invalid if [the accused] had not been aware of the nature of the charges against him, including the elements of the [  ] charge to which he pleaded guilty."  Id. at 182-83.

4.                   The Defendant's guilty plea was not voluntary, knowing, or intelligent, because the Defendant was not aware of the elements of the charge to which she pled guilty.  Accordingly, the guilty plea was invalid and must be set aside, on the grounds that it was obtained in violation of the Defendant's state and federal constitutional rights to due process of law.

5.                   In the words of the MAR statute, the Defendant contends that the conviction must be set aside because it "was obtained in violation of the Constitution of the United States or the Constitution of North Carolina" as described above.  N.C. Gen. Stat. 15A-1415(b)(3).