Gregory D. Valentine, Sr. v. State of Tennessee, M2016-00854-CCA-R3-PC

Gregory D. Valentine, Sr. pleaded "best interest" (guilty) to multiple identity-theft-related charges and received an effective sentence of 12 years 8 months (split between local confinement and probation).
He filed pro se motions to withdraw his pleas, arguing coercion and ineffective assistance; the trial court initially denied them, this court reversed and remanded for a hearing, and the trial court again denied relief.
Valentine then filed a post-conviction petition alleging involuntary pleas, coerced confession, and ineffective assistance of counsel; the post-conviction court initially dismissed but this court remanded for an evidentiary hearing on ineffective assistance only.
At the evidentiary hearing Valentine alleged counsel coerced him (including arranging jail meetings with a co-defendant who urged him to plead and permitting physical contact), threatened he would face an "all-white jury" and harsh sentence, and otherwise pressured him to accept the plea.
The post-conviction court credited trial counsel’s testimony, discredited Valentine and the co-defendant, denied relief, and also denied Valentine’s motion to recuse the post-conviction judge; this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion to recuse post-conviction judge	Judicial-complaint and prior reversals show bias; judge cannot be impartial	Complaint was dismissed; prior appellate rulings are judicial, not extrajudicial; no objective basis for recusal	Denial affirmed — no abuse of discretion, no extrajudicial bias shown
Ineffective assistance — counsel arranged pre-plea meetings and permitted physical contact with co-defendant	Counsel engineered emotional meetings/kisses to coerce plea; performance deficient	Counsel disputed arranging/recalling kisses, was present, deputies nearby; trial court credited counsel	Denied — credibility resolved for counsel; no deficient performance shown
Ineffective assistance — alleged counsel threats ("all-white jury," belligerence, offer-rejection letter)	Counsel threatened jury/rate and pressured to sign rejection form; coerced plea	Counsel denied making those statements; some allegations not raised in post-conviction petition and thus waived	Denied — either not proven, discredited on record, or waived for failure to raise earlier
Voluntariness of guilty plea	Plea was involuntary due to counsel’s deficient performance and coercion	Plea colloquy shows plea was knowing, voluntary; voluntariness already litigated on direct appeal	Denied — voluntariness previously determined on direct appeal; collateral relitigation barred

Strickland v. Washington, 466 U.S. 668 (established two-prong ineffective-assistance standard)
Hill v. Lockhart, 474 U.S. 52 (applying Strickland to guilty-plea context; prejudice requires showing would have gone to trial)
Henley v. State, 960 S.W.2d 572 (deference to trial court credibility findings in post-conviction review)
Goad v. State, 938 S.W.2d 363 (standard for proving deficient performance and prejudice)
Alley v. State, 882 S.W.2d 810 (recusal standard — objective reasonable-basis test)
Hines v. State, 919 S.W.2d 573 (recusal and deference to trial court discretionary decisions)
Fields v. State, 40 S.W.3d 450 (post-conviction review: fact findings given deference)
Kendrick v. State, 454 S.W.3d 450 (appellate review standards for post-conviction factual findings)
Ruiz v. State, 204 S.W.3d 772 (abuse of discretion standard for trial court rulings)