Hills v. State, 101 So. 3d 691

Hills pled guilty to sale of cocaine within 1,500 feet of a church and conspiracy to distribute cocaine in Pike County Circuit Court.
Counts I and II were sentenced concurrently; Counts I 16 years, Count II 20 years with 16 to serve and 4 years post-release supervision.
Hills was sentenced as a habitual offender under Miss. Code Ann. § 99-19-81 and enhanced under § 41-29-142 for sale within 1,500 feet of a church.
Hills filed a post-conviction relief motion, which the trial court dismissed with prejudice.
Hills argues (1) improper habitual-offender sentence, (2) ineffective assistance for failing to object to the indictment, and (3) unconstitutional sentence.
TheCourt affirmed the PCR dismissal, finding no error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether missing judgment dates in the indictment created plain error.	Hills asserts plain error due to missing judgment dates.	State argues sufficient notice in indictment; no plain error.	No plain error; indictment sufficient.
Whether counsel was ineffective for failing to object to the missing dates.	Hills contends ineffective assistance under Strickland.	State argues no reasonable probability the outcome would differ.	Meritless; no prejudicial effect shown.
Whether Hills's sentence was illegal due to missing judgment dates.	Hills claims illegality/ due-process violation.	State reiterates sufficient notice and proper enhancement.	Without merit.

Williams v. State, 872 So.2d 711 (Miss. Ct. App. 2004) (standard for reviewing PCR dismissal on evidence of error)
Brown v. State, 731 So.2d 595 (Miss. 1999) (de novo standard for legal issues in PCR review)
Flora v. State, 925 So.2d 797 (Miss. 2006) (plain-error rule for trial objections)
Mitchell v. State, 58 So.3d 59 (Miss. Ct. App. 2011) (indictment sufficiency for habitual-offender notice)
Hannah v. State, 943 So.2d 20 (Miss. 2006) (Strickland two-prong standard for ineffective assistance)