Casey J. Lawson v. State of Tennessee
M2016-00403-CCA-R3-PC
| Tenn. Crim. App. | Apr 13, 2017Background
- Petitioner Casey J. Lawson pleaded guilty to unlawful possession of a weapon by a convicted felon and theft of property valued >$1,000 but <$10,000.
- Plea occurred after negotiated terms and a detailed Rule 11 colloquy; petitioner was aware of consequences and restitution obligations.
- Trial counsel advised pleading to both offenses as a strategic choice to avoid harsher outcome at trial.
- Two bond-revocation motions and a potential misconduct/fitness record context surrounded the cases; some motions remained undecided.
- Post-conviction relief denied; appellate review upheld denial after finding no ineffective assistance or involuntariness.
- Plea court conduct and timing of motions were evaluated against standards for voluntariness and effective assistance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for plea advice | Lawson argues counsel erred in advising plea. | State contends advice was strategic and within norms. | No deficient performance; advice within reasonable strategic bounds. |
| Failure to argue pending motions before plea | Counsel failed to rule on motions that could affect outcome. | Motions were unrelated to theft; not ineffective to delay ruling. | No deficiency; motions deferred appropriately. |
| Guilty plea involuntary due to coercion | Threats of bond revocation coerced plea. | No coercion; plea canvass and circumstances show voluntariness. | Plea voluntary; no coercion found. |
| Cumulative error analysis | Multiple supposed errors cumulatively prejudicial. | No single or cumulative error undermines plea validity. | No cumulative error; relief denied. |
Key Cases Cited
- Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (necessity of knowing and voluntary plea; right to informed decision)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance of counsel)
- Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (prejudice standard for guilty pleas)
- Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (definitions of deficient performance and prejudice)
- Henley v. State, 960 S.W.2d 579 (Tenn. 1997) (counsel’s performance and standard of review)
- Blankenship v. State, 858 S.W.2d 897 (Tenn. 1993) (plea voluntariness factors and court canvass requirements)
- Turner v. State, 919 S.W.2d 346 (Tenn. Crim. App. 1995) (totality of circumstances in voluntariness inquiry)
- Pettus v. State, 986 S.W.2d 540 (Tenn. 1999) (federal and state standards for knowing pleas and punishment consequences)
- Jaco v. State, 120 S.W.3d 828 (Tenn. 2003) (standard for post-conviction proof and review)
