Derrell Woods v. State of Indiana
2015 Ind. App. LEXIS 773
| Ind. Ct. App. | 2015Background
- Derrell Woods appealed a post-conviction court denial of an amended petition arguing ineffective assistance of trial counsel.
- Woods was charged with Robbery (Class A felony) with related charges; his codefendant pled guilty to related offenses in a separate matter.
- A June 23, 2003 letter from the prosecutor offered Woods a plea to Robbery (Class B) and two Class D felonies with dismissal of the carjacking charge, with sentencing to be set by the court and a Thursday deadline.
- Woods' counsel allegedly failed to communicate this offer to Woods; Woods testified he would have accepted the offer if informed.
- The post-conviction court found the record insufficient to prove the offer or its communication, and denied relief.
- The Court of Appeals reversed, holding the offer existed and was not properly communicated, violating Strickland and Frye/Lafler standards; remanded with instructions related to the accepted/rejected plea offer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Zook’s failure to communicate the June 23, 2003 plea offer deprived Woods of effective counsel | Woods | State | Yes; Zook’s communication failure was deficient and prejudicial, warranting reversal |
Key Cases Cited
- Missouri v. Frye, 132 S. Ct. 1399 (U.S. 2012) (duty to communicate formal plea offers with fixed expiration date)
- Lafler v. Cooper, 132 S. Ct. 1376 (U.S. 2012) (prejudice from counsel’s bad plea advice; reasonable probability of better outcome)
- Dew v. State, 843 N.E.2d 556 (Ind. Ct. App. 2006) (prejudice standard for uncommunicated plea offers)
- Overstreet v. State, 877 N.E.2d 144 (Ind. 2007) (clear-error standard for post-conviction findings)