Crystal B. Williams v. State, 04-16-00431-CR

Appellant Crystal Williams was indicted for causing serious bodily injury to her five-year-old stepson by two alternate means: (A) failing to provide adequate nourishment and (B) failing to obtain and provide proper medical care; she pleaded not guilty to A and guilty to B before a jury.
The trial court admonished Williams on her guilty plea, found it voluntary, and instructed the jury to find her guilty under Paragraph B; the jury convicted after ~4 minutes.
At punishment the jury heard evidence and assessed 99 years’ confinement and a $10,000 fine.
On appeal Williams contended trial counsel was ineffective for allowing her to plead guilty because the State presented no independent evidence at guilt-innocence proving that proper medical care would have prevented the child’s serious injury or death.
Williams relied on Tex. Code Crim. Proc. art. 1.15 (requiring evidence independent of a plea when a jury trial is waived), but acknowledged that article 1.15 does not apply where a jury determines guilt.
The court addressed ineffective-assistance standards (Strickland/Hill), found the appellate record does not affirmatively show deficient performance or prejudice, and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was counsel ineffective for allowing Williams to plead guilty to the jury?	Counsel was deficient because the State presented no evidence, independent of her plea, at guilt-innocence to prove serious bodily injury causation; thus plea deprived her of appellate review of sufficiency.	Counsel’s advice could have been strategic; the record does not affirmatively show deficient performance or that Williams would have insisted on trial (no prejudice under Hill).	Court held Williams failed both Strickland prongs: record does not show deficient performance and she failed to prove prejudice; claim denied.

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance test: deficient performance and prejudice)
Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for guilty-plea challenges: reasonable probability defendant would have gone to trial)
Thompson v. State, 9 S.W.3d 808 (Tex. Crim. App. 1999) (appellate review requires record to affirmatively demonstrate ineffective assistance)
Menefee v. State, 287 S.W.3d 9 (Tex. Crim. App. 2009) (article 1.15 requires evidence independent of plea when jury trial is waived)
Wright v. State, 28 S.W.3d 526 (Tex. Crim. App. 2000) (article 1.15 applies only when jury trial is waived)
Young v. State, 991 S.W.2d 835 (Tex. Crim. App. 1999) (courts must presume counsel’s actions are part of strategy unless record shows otherwise)
Wilkerson v. State, 736 S.W.2d 656 (Tex. Crim. App. 1987) (guilty plea before a jury admits all incriminating facts necessary to establish guilt)
Ex parte Tuley, 109 S.W.3d 388 (Tex. Crim. App. 2002) (defendants may plead guilty for reasons unrelated to factual guilt, reflecting strategic choices)