Edward Trotter v. Darrel Vannoy, Warden, 695 F. App'x 738

Trotter was convicted in 2001 of drug offenses and initially sentenced as a habitual offender to life without benefits; that conviction was vacated on federal habeas review in 2010 for a Batson violation.
After vacatur, prosecutors offered a plea: plead guilty as a second-felony offender to one possession count (28–200g cocaine) in exchange for a 30-year sentence, credit for time served, dismissal of other charges, and no further habitual-offender enhancements.
At the plea hearing the court advised Trotter of rights waived, the minimum/maximum sentence and fines, and admonished that as a second-felony offender he faced 15–60 years; the court accepted the guilty plea and imposed 30 years hard labor "without benefit of probation, parole, or suspension of sentence."
After sentencing the court made speculative remarks that Trotter might be eligible for parole and noted DOC would ultimately decide parole eligibility; DOC later determined Trotter was not parole-eligible because of four felony convictions.
Trotter sought state post-conviction relief claiming his plea was involuntary due to an unfulfilled promise of parole eligibility and that counsel was ineffective for advising him he would be eligible for parole; state courts denied relief and the federal district court denied habeas relief.
The Fifth Circuit affirmed, concluding the plea did not rest on any promise of parole and counsel’s performance was not shown to be deficient or prejudicial under Strickland.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Trotter's guilty plea was involuntary because it was induced by a promise he would be eligible for parole	Trotter: plea was induced by an unfulfilled promise or understanding that he would be parole-eligible	State: plea terms did not include parole eligibility; court fully admonished Trotter and informed him of sentencing consequences; parole is determined by DOC	Denied — plea was knowing and voluntary; no promise regarding parole was part of the plea agreement and court admonitions undermined the claim
Whether counsel was ineffective for advising or persuading Trotter to plead based on parole eligibility	Trotter: counsel told him he would be eligible for parole, so counsel’s advice was deficient and prejudicial	State: record does not show counsel promised parole or performed below objective standard; court admonitions contradict claim; no prejudice shown	Denied — Strickland not satisfied; no deficient performance or resulting prejudice

Batson v. Kentucky, 476 U.S. 79 (prohibition on race-based juror strikes)
Santobello v. New York, 404 U.S. 257 (prosecutorial promises that induce a plea must be fulfilled)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance standard)
Cullen v. Pinholster, 563 U.S. 170 (deferential AEDPA review standard for federal habeas)