Holder v. State
2011 Miss. App. LEXIS 356
| Miss. Ct. App. | 2011Background
- Holder was indicted for burglary of a dwelling and capital murder.
- He pleaded not guilty at first, then pled guilty after a plea deal reduced capital murder to manslaughter.
- Sentences: 20 years for manslaughter and 20 years for burglary, to run consecutively, under MDOC custody.
- On May 27, 2010, Holder filed a PCR motion claiming involuntary, unintelligent pleas and ineffective assistance of counsel, supported by multiple affidavits and statements.
- The Jones County Circuit Court dismissed the PCR motion without an evidentiary hearing; Holder appealed.
- The appellate court affirmed the dismissal, holding pleas voluntary and no merit to ineffective-assistance claims or need for an evidentiary hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Were the guilty pleas voluntary and intelligent? | Holder argues pleas were involuntary due to counsel's advisement. | State contends the plea colloquy shows voluntariness and intelligent understanding. | Plea voluntary and intelligent; no error in dismissal. |
| Did Holder have ineffective assistance of counsel warranting relief? | Holder asserts counsel deficient; claimed Strickland violation. | State contends failure to prove Strickland prongs; no prejudice shown. | No Strickland showing; no relief. |
| Was an evidentiary hearing required on the PCR motion? | Holder sought an evidentiary hearing. | State argues no factual basis supporting relief; hearing unnecessary. | District court did not abuse discretion; no evidentiary hearing required. |
Key Cases Cited
- Ward v. State, 879 So.2d 452 (Miss. Ct. App. 2003) (great weight given to statements under oath)
- Gable v. State, 748 So.2d 703 (Miss. 1999) (court may rely on in-court swearing)
- King v. State, 738 So.2d 240 (Miss. 1999) (plea validity requires voluntariness and intelligence)
- Harris v. State, 806 So.2d 1127 (Miss. 2002) (advisement of rights and consequences in plea)
- Burrough v. State, 9 So.3d 368 (Miss. 2009) (context for post-conviction standards)
- Havard v. State, 988 So.2d 322 (Miss. 2008) (Strickland prongs apply to pleas)
- Mason v. State, 42 So.3d 629 (Miss. Ct. App. 2010) (valid guilty plea waives non-jurisdictional rights)
- Dennis v. State, 873 So.2d 1045 (Miss. Ct. App. 2004) (plea-related admissibility of claims)
- Williams v. State, 872 So.2d 711 (Miss. Ct. App. 2004) (standard for PCR motion dismissal review)
- Kinney v. State, 737 So.2d 1038 (Miss. Ct. App. 1999) (Strickland analysis application)
- Ivy v. State, 31 So.3d 643 (Miss. Ct. App. 2009) (ineffective-assistance standard accompanying guilty pleas)
- Ward v. State, 879 So.2d 452 (Miss. Ct. App. 2003) (weight of sworn statements in open court)
- Gable v. State, 748 So.2d 703 (Miss. 1999) (recited above)