Darien B. Clay v. State of Tennessee, E2015-02107-CCA-R3-PC

Darien B. Clay pleaded guilty pursuant to a negotiated plea that disposed of 18 counts across multiple indictments; he received an effective 13-year sentence (8 years at 85% + 5 years at 30%).
Clay later petitioned for post-conviction relief, claiming ineffective assistance of counsel and that his plea was not knowing and voluntary because counsel misrepresented the terms (calling it a “universal plea”) and led him to believe sentences would be concurrent and that he would serve only ~2 years.
At the post-conviction hearing Clay and his mother testified they were told by counsel the sentence exposure would be much lower and that Clay did not fully review or understand the plea paperwork before pleading.
Counsel testified he repeatedly explained the plea terms (effective 13 years with the first 8 at 85%), met multiple times with Clay and his mother, prepared for trial, and used “universal” only to mean a single agreement resolving all pending matters.
The post-conviction court credited counsel’s testimony over Clay’s, found counsel’s performance not deficient, that Clay’s plea was knowingly and voluntarily entered, and denied relief. The Court of Criminal Appeals affirmed.

Issue	Petitioner (Clay) Argument	State (Defendant) Argument	Held
Ineffective assistance of counsel	Counsel misled Clay about plea terms, used “universal plea” to imply concurrent sentences, causing Clay to accept plea he otherwise would not	Counsel thoroughly explained terms, prepared for trial, and the record shows Clay and his mother understood the offer; trial court credited counsel	Denied — court credited counsel; performance not deficient and no prejudice under Strickland
Voluntary and knowing plea	Clay did not understand sentence length or consecutive service; his affirmative responses at plea were due to counsel’s direction, not understanding	Clay’s on-the-record statements at plea acknowledged understanding; trial court reviewed terms; plea was voluntary and intelligent	Denied — plea found knowing and voluntary; Clay’s in-court acknowledgments and record control

Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective assistance test: performance and prejudice)
Henley v. State, 960 S.W.2d 572 (Tenn. standard: post‑conviction factual findings binding unless record preponderates otherwise)
Blackledge v. Allison, 431 U.S. 63 (statements under oath at plea hearing carry strong presumption of verity in collateral proceedings)
Boykin v. Alabama, 395 U.S. 238 (trial court must ensure defendant understands consequences of plea)
North Carolina v. Alford, 400 U.S. 25 (guilty plea must represent voluntary and intelligent choice)