Goins v. State
726 S.E.2d 1
S.C.2012Background
- Goins pled guilty to two possession-with-intent-to-distribute charges for crack cocaine, receiving a ten-year sentence concurrent on both counts after the State dropped distribution charges.
- Police entered Goins’ motel room without a warrant or valid consent; Goins alleged the drugs were seized unlawfully in the room and on his person.
- Goins acknowledged in plea colloquy that pleading guilty would prevent him challenging the evidence as illegally obtained.
- At PCR, Goins claimed plea counsel misadvised him that the drugs were lawfully seized and that suppression would fail; counsel testified to expectations of suppression challenges and the State’s drop of charges.
- The PCR court found Goins’ credibility not credible, and that Goins would have faced a suppressed evidence outcome unlikely to yield a different result; the court also criticized a misleading statement by counsel about landlord consent.
- We granted certiorari to review whether plea counsel’s allegedly faulty advice was prejudicial and whether the PCR court erred in denying relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was counsel deficient for advising on suppression law? | Goins | Goins | No clear deficiency; but the advice was erroneous |
| Did Goins show prejudice from counsel's alleged erroneous advice? | Goins | Goins | No prejudice; Goins would have accepted the plea offer anyway |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance)
- Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (reasonable probability to plead guilty instead of going to trial)
- Lomax v. State, 379 S.C. 93 (S.C. 2008) (PCR burden; credibility of findings reviewed)
- Edwards v. State, 392 S.C. 449 (S.C. 2011) (presumption of reasonable professional judgment)
- Simuel v. State, 390 S.C. 267 (S.C. 2010) (great deference to PCR credibility determinations)
- Stalk v. State, 383 S.C. 559 (S.C. 2009) (reasonable probability standard for guilty plea plea withdrawal)
- State v. Freiburger, 366 S.E.2d 125 (S.C. 2005) (searches incident to arrest; contemporaneousness and proximity to arrest)