Charles Edgar Ledford v. State of Tennessee, E2016-00208-CCA-R3-PC

Background

Ledford pled guilty to multiple child-sex offenses after the trial court denied a suppression motion; the evidence included videos found during enforcement of a condemnation order. He received an effective 56-year sentence.
On direct appeal this Court upheld the search and seizure, concluding Ledford had abandoned the property. See State v. Ledford, 438 S.W.3d 543.
Ledford filed a pro se post-conviction petition alleging (inter alia) ineffective assistance of trial counsel causing an involuntary guilty plea and ineffective assistance at sentencing; counsel was later appointed but did not file an amended petition per a scheduling order.
At the evidentiary hearing Ledford testified counsel coerced him into pleading, failed to explain sentencing exposure or concurrent vs. consecutive sentences, and did not fully investigate or present mental-health mitigation; trial counsel testified he investigated, reviewed videos with Ledford, explained risks (including federal prosecution), and thought plea was in Ledford’s best interest.
The post-conviction court accredited trial counsel’s testimony, found Ledford not credible, and excluded re-litigation of the suppression ruling as previously determined; it denied relief.
On appeal Ledford challenged counsel’s performance (guilty plea and sentencing), the exclusion of evidence about the search, and asserted post-conviction counsel violated Tenn. Sup. Ct. R. 28; the Court affirmed denial of relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance at guilty plea (coercion; inadequate advice)	Ledford: counsel coerced plea, visited little, failed to explain sentencing exposure and concurrent vs. consecutive sentences.	State/Trial counsel: counsel investigated, reviewed evidence with Ledford, explained sentencing range and federal-risk, and did not coerce; Ledford affirmed plea in court.	Denied — court credited counsel, plea colloquy and record rebut Ledford; no Strickland prejudice shown.
Ineffective assistance at sentencing (failure to present mental-health mitigation; competency)	Ledford: counsel failed to stop sentencing after pre-sentencing self-harm and failed to present mental-health history as mitigation.	State/Trial counsel: counsel evaluated mental-health records, procured evaluation, asked for delay, and reasonably concluded mental-health defense was not viable.	Denied — Ledford produced no favorable evidence; counsel’s investigation was reasonable; no prejudice shown.
Reopening/relitigating suppression (search of house)	Ledford: sought to introduce facts about the search and argue counsel failed to investigate suppression grounds.	State: suppression issue previously determined on direct appeal; post-conviction petition did not allege ineffective investigation; no offer of proof.	Denied — constitutional search issue previously decided; post-conviction court properly excluded re-litigation and excluded unpled ineffective-assistance theory.
Post-conviction counsel’s Rule 28 violations	Ledford: counsel failed to file amended petition or required certification and allegedly abandoned him, warranting a new hearing.	State: Rule 28 violations do not, by themselves, entitle petitioner to relief; Ledford received a full and fair hearing.	Denied — despite counsel’s noncompliance, Ledford received a meaningful opportunity to be heard; no relief warranted.

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (establishes two-prong test for ineffective assistance of counsel)
Hill v. Lockhart, 474 U.S. 52 (prejudice standard for ineffective assistance in guilty plea context)
Blackledge v. Allison, 431 U.S. 63 (recorded plea colloquy carries strong presumption of verity)
Burns v. State, 6 S.W.3d 453 (deference to counsel’s tactical decisions when made after adequate preparation)
State v. Ledford, 438 S.W.3d 543 (Tenn. Crim. App.) (direct appeal upholding search/abandonment ruling)
Frazier v. State, 303 S.W.3d 674 (post-conviction counsel duties under Tenn. R. Sup. Ct. 28 and limits on relief for counsel errors)