Beasley v. State
298 Ga. 49
| Ga. | 2015Background
- In 2004 Beasley was indicted for malice murder, two counts of felony murder, aggravated assault, burglary, and two counts of possession of a knife in connection with the death of his ex-girlfriend.
- After a competency evaluation found him fit to proceed, Beasley changed counsel and in 2006 pled guilty (negotiated plea) to felony murder and possession of a knife during the commission of a crime.
- Beasley filed multiple post-conviction motions, including a 2009 habeas petition raising ineffective-assistance and voluntariness-of-plea claims; the habeas court denied relief and this Court dismissed his certificate application as untimely in 2014.
- In 2014 Beasley moved for an out-of-time appeal (and for appointment of counsel); the trial court denied the amended motion and he appealed that denial pro se to the Supreme Court of Georgia.
- The Supreme Court held most of Beasley’s claims were precluded by res judicata because they had been or could have been litigated in the prior habeas proceeding, and affirmed the denial of the out-of-time appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel | Beasley: counsel failed to provide effective assistance at plea and related proceedings | State: claim was litigated in habeas and precluded by res judicata | Court: precluded by res judicata; denied |
| Voluntariness of plea (intent element) | Beasley: plea was unknowing because he wasn’t told intent was an element | State: claim raised in habeas; precluded now | Court: precluded by res judicata; denied |
| Nolle prosequi to aggravated assault with guilty plea to felony murder predicated on that act | Beasley: trial court erred entering nolle prosequi then accepting felony-murder plea predicated on that conduct | State: claim raised in habeas; precluded now | Court: precluded by res judicata; denied |
| Trial court duty to inquire sua sponte into competency | Beasley: trial court should have sua sponte ordered a competency inquiry before accepting plea | State: issue could have been raised in habeas; no record evidence raised bona fide doubt of competence; trial court not required to inquire absent indication | Court: issue precluded by res judicata; alternatively no evidence of bona fide doubt so no sua sponte duty; denied |
Key Cases Cited
- Wiggins v. State, 288 Ga. 169 (discussing res judicata and preclusion of habeas-relitigated claims)
- Body of Christ Overcoming Church of God v. Brinson, 287 Ga. 485 (res judicata bars claims that could have been adjudicated previously)
- Davis v. State, 287 Ga. 414 (affirmance under "right for any reason" principle)
- Lytle v. State, 290 Ga. 177 (no sua sponte competency inquiry required absent indicia of incompetence)
- Burch v. State, 293 Ga. 816 (out-of-time appeal from guilty plea only available where issues can be resolved from the record)