Clarence Tyrone Pruitt v. State of Tennessee, W2015-02133-CCA-R3-PC

Pruitt was indicted on two counts of aggravated rape; pleaded guilty to one count pursuant to a plea agreement for a 20-year sentence and one count was dismissed. The plea judgment recommended placement at DeBerry Special Needs Facility (sex-offender and mental-health treatment unit).
State’s plea proof included a victim’s account of a violent sexual assault and a DNA match linking Pruitt to the rape kit sample. The State’s initial offer was 25 years at 100%; defense secured a 5-year reduction to 20 years.
Trial counsel obtained a mental-health evaluation finding Pruitt competent to stand trial; counsel believed Pruitt understood the proceedings and did not appear confused. Counsel conceded she did not follow up with a letter to secure DeBerry placement.
Pruitt has a history of many prior convictions, including a prior sex offense, and had pleaded guilty to numerous prior charges; he was familiar with plea proceedings.
Pruitt alleged in a pro se and amended post-conviction petition that counsel was ineffective for failing to account for his mental illness at the plea hearing and that his plea was unknowing and involuntary because he was off his medications and hoped for placement at DeBerry.
At the evidentiary hearing the post-conviction court found Pruitt not credible, credited counsel’s testimony that Pruitt understood the plea, and denied relief; Pruitt appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of counsel	Pruitt: counsel failed to account for his mental illness/medication status at plea, rendering representation deficient and causing involuntary plea	State: counsel obtained competency evaluation, consulted discovery, negotiated a favorable reduction, and did not act deficiently; Pruitt was lucid and communicative	Denied — counsel’s performance not deficient; no prejudice shown under Strickland because Pruitt would not likely have insisted on trial given evidence and sentence exposure
Knowing and voluntary nature of plea	Pruitt: plea unknowing/involuntary because he was off prescribed meds and wanted DeBerry placement (would not have pled if medicated or guaranteed DeBerry)	State: record shows plea colloquy, Pruitt’s criminal experience, counsel’s advice, and Pruitt’s own statements that he understood the plea; lack of medication did not render plea involuntary	Denied — plea was knowing and voluntary; circumstantial factors and colloquy support voluntariness

Strickland v. Washington, 466 U.S. 668 (1984) (two-part ineffective-assistance test: deficient performance and prejudice)
Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice in plea context requires reasonable probability defendant would have gone to trial)
Boykin v. Alabama, 395 U.S. 238 (1969) (plea must be voluntary and knowing)
Blankenship v. State, 858 S.W.2d 897 (Tenn. 1993) (factors for evaluating voluntariness of plea)
Wiley v. State, 183 S.W.3d 317 (Tenn. 2006) (post-conviction factual findings afforded deference on appeal)