Elbert Bryant Gleaves v. State of Tennessee, M2016-02371-CCA-R3-PC

Petitioner Elbert Bryant Gleaves faced multiple indictments (theft, aggravated assault, aggravated robbery, carjacking, firearm use, evading, leaving scene) and was represented by court‑appointed trial counsel after replacing juvenile counsel.
State offered a plea: concurrent sentences totaling ten years (with 85% release eligibility); other counts to be dismissed; petitioner accepted and pled guilty to theft, two aggravated assaults, and aggravated robbery.
Petitioner later filed a pro se post‑conviction petition claiming trial counsel failed to investigate and pressured him into pleading guilty, so his plea was not knowing, voluntary, and intelligent.
The post‑conviction court held an evidentiary hearing, credited trial counsel’s testimony that he interviewed officers and reviewed reports, and found counsel’s investigation adequate and the plea knowing and voluntary.
The court denied relief; petitioner appealed to the Tennessee Court of Criminal Appeals, which affirmed the denial, finding no deficient performance or prejudice sufficient to satisfy Strickland/Hill standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel’s failure to investigate was ineffective assistance	Counsel met only once or twice and did not contact state witnesses, so representation was deficient	Counsel interviewed officers, reviewed reports, and adequately advised client; case facts favored conviction	Counsel’s investigation was credited; no deficient performance found
Whether petitioner’s guilty plea was knowing, voluntary, intelligent	Plea induced by counsel’s deficiencies and pressure to accept a 10‑year deal; not made knowingly	Plea colloquy and counsel’s advisement show petitioner understood rights, consequences, and alternatives	Plea was knowingly, voluntarily, intelligently entered; not coerced
Whether prejudice existed to satisfy Strickland/Hill (i.e., would outcome differ but for counsel’s errors)	But for counsel’s errors, petitioner would have gone to trial and not pled	Case was a “slam dunk” for State; trial likely would have led to longer sentence than plea	No reasonable probability of a different result; prejudice not established
Whether post‑conviction court’s factual findings should be disturbed on appeal	Post‑conviction findings were erroneous due to miscrediting petitioner	Trial court credited counsel and factual record supports findings	Appellate court defers to credibility findings; no preponderant evidence to overturn

Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective assistance test: deficient performance and prejudice)
Hill v. Lockhart, 474 U.S. 52 (applies Strickland to challenges to guilty pleas; requires showing reasonable probability defendant would not have pled)
Goad v. State, 938 S.W.2d 363 (Tenn. Crim. App. standard on attorney performance and deference to strategy)
Henley v. State, 960 S.W.2d 572 (deference to post‑conviction court credibility findings)
Tidwell v. State, 922 S.W.2d 497 (post‑conviction factual findings are conclusive unless evidence preponderates against them)