J.W. Causey v. State of Tennessee
W2017-00470-CCA-R3-PC
| Tenn. Crim. App. | Dec 19, 2017Background
- Defendant J.W. Causey (19 at time) convicted by jury of first-degree premeditated murder (2013) and sentenced to life; direct appeal denied.
- Shooting occurred Dec. 17, 2010 at a hotel: eyewitnesses testified Causey confronted and shot 17-year-old William Bibb in the chest while Bibb had his hands raised.
- Causey gave a written statement admitting he got a gun, confronted the victim, and shot him; he did not testify at trial.
- First trial resulted in a hung jury; prosecution later offered a 30-year plea before the second trial according to trial counsel; Causey denied ever receiving such an on-the-record offer and said he would have accepted it.
- Causey filed a timely pro se post-conviction petition alleging ineffective assistance of counsel (limited to failure to convey the 30-year plea offer).
- Post-conviction court credited trial counsel’s testimony that he conveyed the offer and Causey rejected it, found no deficient performance or prejudice, and denied relief; Court of Criminal Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Causey was denied effective assistance because counsel failed to convey a 30-year plea offer | Causey: counsel never informed him of a 30-year offer in open court; he would have accepted it, so he was prejudiced | State/Counsel: counsel testified he conveyed the 30-year offer after the hung jury and Causey rejected it | Court: Credited counsel; Causey failed to prove deficient performance or prejudice; post-conviction relief denied |
Key Cases Cited
- Momon v. State, 18 S.W.3d 152 (Tenn. 1999) (appellate deference to post-conviction court credibility findings)
- Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (post-conviction factual findings given weight of jury verdict)
- Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (post-conviction conclusions of law receive no deference)
- Baxter v. Rose, 523 S.W.2d 930 (Tenn. 1975) (standard for competent assistance of counsel)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
- Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (application of Strickland in Tennessee)
- Kendrick v. State, 454 S.W.3d 450 (Tenn. 2015) (strong presumption that counsel’s decisions are reasonable)