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Casey J. Lawson v. State of Tennessee
M2016-00403-CCA-R3-PC
| Tenn. Crim. App. | Apr 13, 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: Casey J. Lawson v. State of Tennessee
Court Name: Court of Criminal Appeals of Tennessee
Date Published: Apr 13, 2017
Docket Number: M2016-00403-CCA-R3-PC
Court Abbreviation: Tenn. Crim. App.