Beal v. State, 58 So. 3d 709

Beal pled guilty to one count of statutory rape in Madison County Circuit Court on May 27, 2009.
Beal was sentenced to 27 years in the Mississippi Department of Corrections.
Beal filed a motion for post-conviction relief; the trial court dismissed it.
Beal appeals raising four issues: timely initial appearance, constitutional rights, ineffective assistance of counsel, and voluntariness of the guilty plea.
The court applies de novo review to legal conclusions and clearly erroneous standard to factual findings when reviewing post-conviction relief denials.
The appellate court affirms the circuit court’s dismissal of the post-conviction relief motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timely initial appearance	Beal argues denial of a timely initial appearance.	State contends issues waived by guilty plea.	Issues meritless; waiver by guilty plea.
Constitutional rights violated by delay	Beal asserts constitutional rights were violated by delay in initial appearance.	State relies on waiver and lack of merit.	Issues meritless; waivers apply.
Ineffective assistance of counsel	Beal contends counsel failed to raise initial-appearance issue.	State argues no deficiency or prejudice established.	No deficient performance; issue lacks particularized showing.
Voluntariness of guilty plea	Beal asserts timing influenced plea decision.	Plea colloquy informed of consequences; timing irrelevant.	Plea found voluntary and intelligent.

Davis v. State, 967 So.2d 1269 (Miss.Ct.App.2007) (waiver of initial-appearance challenges upon valid guilty plea)
Battaya v. State, 861 So.2d 364 (Miss.Ct.App.2003) (initial-appearance challenges waived post-plea)
Strickland v. Washington, 466 U.S. 668 (U.S.1984) (ineffective-assistance standard requiring deficient performance and prejudice)
Alexander v. State, 605 So.2d 1170 (Miss.1992) (voluntariness requires proper advisement and understanding of consequences)