Camp v. State
2015 Ark. 90
| Ark. | 2015Background
- Defendant Wyouman David Camp was offered a 20-year plea for pleading guilty to charges related to the murder of his estranged wife but rejected the offer and proceeded to trial.
- At trial, co-defendant Harry Surber testified Camp and Camp’s sister Jo Ann Hicks hired him to kill Robin Camp; jury convicted Camp of first-degree murder and sentenced him to life.
- Trial counsel Paul Hoover (deceased) represented Camp; Camp later sought postconviction relief under Ark. R. Crim. P. 37.1 alleging ineffective assistance for advising him to reject the plea.
- Camp’s pro se Rule 37 petition raised multiple ineffective-assistance claims; after counsel was appointed he pursued the claim that Hoover failed to inform him of the strength of the State’s evidence so he would have accepted the 20-year plea.
- At an in-chambers plea colloquy before trial, Camp acknowledged knowledge of the 20-year offer, that he declined it, and that he knew generally what testimony was coming; at the Rule 37 hearing Camp recanted, asserting he would have accepted the plea if fully informed.
- The circuit court denied relief, finding Camp’s Rule 37 testimony self-serving and contradictory to his prior statements; the Arkansas Supreme Court affirmed.
Issues
| Issue | Camp's Argument | State's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for advising Camp to reject the State's 20-year plea by failing to inform him of the strength of the State's evidence | Hoover failed to disclose the severity/contents of the State’s evidence (witnesses and testimony), so Camp would have accepted the 20-year plea | Evidence (trial testimony, attempts to hire a killer, and Camp's earlier plea colloquy) shows Camp knew the evidence; Camp’s Rule 37 testimony is self-serving and contradicted prior statements | Affirmed — no relief. Court found Camp’s Rule 37 testimony contradicted his in-court plea statements and failed to show deficient performance under Strickland or resulting prejudice |
Key Cases Cited
- Montgomery v. State, 2011 Ark. 462, 385 S.W.3d 189 (standard for appellate review of Rule 37 factual findings)
- Sales v. State, 2014 Ark. 384, 441 S.W.3d 883 (Strickland standard applied in Arkansas)
- Anderson v. State, 2011 Ark. 488, 385 S.W.3d 783 (prejudice prong and Strickland analysis)
- Strickland v. Washington, 466 U.S. 668 (two-prong test for ineffective assistance of counsel)
- Heard v. State, 2012 Ark. 67 (fact-finder may disbelieve self-interested testimony of the accused)