Calvert v. State, 342 S.W.3d 477

Calvert was indicted in July 2006 on multiple counts of sexual offenses and pled guilty on November 14, 2006 to several counts, receiving a ten-year effective sentence with nine months in jail and the remainder on probation, all to be served concurrently.
The plea petition did not reference a lifetime community supervision consequence, though some rape counts carried a mandatory lifetime supervision provision under Tenn. Code Ann. § 39-13-524(a) that would follow probation.
Defense counsel did not inform Calvert about the mandatory lifetime community supervision; the trial court also did not inform him of this consequence at the plea hearing.
Calvert learned after release on probation that there would be an additional fifteen years of supervision following completion of probation; testing this information later influenced his decision-making about the plea.
Calvert filed a post-conviction petition alleging ineffective assistance of counsel based on failure to inform of consequences, among other claims; a two-lawyer defense team testified at the hearing.
The post-conviction court denied relief; the Court of Criminal Appeals affirmed, and the Tennessee Supreme Court granted review to address whether counsel’s failure to inform about lifetime supervision constituted deficient performance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did counsel's failure to inform about lifetime community supervision amount to deficient performance and prejudice?	State argues no deficient performance or prejudice.	Calvert contends counsel failed to inform him of the lifetime supervision consequence and that this affected his decision.	Yes; deficient performance with prejudice established.
Do Calvert's other alleged deficiencies (trial preparation/pressure) warrant relief?	State maintains no relief for these grounds.	Calvert asserts other deficiencies coerced or confused him into pleading.	No relief on these grounds.

Hill v. Lockhart, 474 U.S. 52 (1985) (applies Strickland test to guilty pleas)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance)
Grindstaff v. State, 297 S.W.3d 208 (Tenn. 2009) (guidance on advising sentencing consequences and deficiency)
Padilla v. Kentucky, 559 U.S. 356 (2010) (counsel must inform about deportation risk)
Ward v. State, 315 S.W.3d 461 (Tenn. 2010) (lifetime community supervision deemed an additional part of sentence)