Jacob Lee Carney v. State of Tennessee, M2025-01775-CCA-R3-PC

At age seventeen, Carney was indicted for murdering his grandmother and attempting to murder his grandmother’s fiancé, and the case was transferred from juvenile to circuit court. 1
Carney pleaded guilty as charged in exchange for a life sentence for murder and a concurrent fifteen-year sentence for attempted murder. 2
At the plea hearing, the State’s factual basis showed Carney attacked the victims with a knife in the home, stabbed his grandmother multiple times, and she died at the scene. 3
Carney told the court he understood the plea and rights waiver, and he said he was satisfied with counsel’s representation before the court accepted the plea. 4
Carney later sought post-conviction relief, alleging he did not understand the plea, counsel pressured him, and counsel failed to present abuse allegations against the fiancé. 5
After an evidentiary hearing with testimony from Carney and counsel, the post-conviction court denied relief and found the plea voluntary and counsel effective. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failure to pursue abuse allegations 7	Carney said counsel ignored evidence that Williard abused him as a child.	The State said counsel investigated and made a reasonable strategic choice.	No ineffective assistance; Carney proved neither deficient performance nor prejudice. 8
Involuntary, unknowing guilty plea 9	Carney claimed mental instability and counsel pressure made the plea involuntary.	The State said the plea colloquy and hearing testimony showed a knowing, voluntary plea.	No; Carney failed to overcome his plea colloquy admissions. 10
Overall post-conviction entitlement 11	Carney sought reversal of the denial of post-conviction relief.	The State argued Carney failed to meet his burden under the Post-Conviction Procedure Act.	Affirmed; Carney was not entitled to relief. 12

Rigger v. State, 341 S.W.3d 299 (Tenn. Crim. App. 2010) (post-conviction claim that a plea was not voluntarily and knowingly entered 13)
Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (guilty pleas must be knowing, intelligent, and voluntary 14)
Phillips v. State, 647 S.W.3d 389 (Tenn. 2022) (ineffective assistance and involuntary plea claims are cognizable in post-conviction proceedings 15)
Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (mixed questions of law and fact reviewed de novo; factual findings presumed correct 16)
Lane v. State, 316 S.W.3d 555 (Tenn. 2010) (mixed questions of law and fact review standard 17)
Kendrick v. State, 454 S.W.3d 450 (Tenn. 2015) (strong presumption counsel provided reasonable professional assistance 18)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (deficient performance and prejudice standard 19)
Dellinger v. State, 279 S.W.3d 282 (Tenn. 2009) (clear-and-convincing burden interacts with Strickland analysis 20)
Black v. State, 794 S.W.2d 752 (Tenn. Crim. App. 1990) (failure to present supporting witnesses at the hearing defeats prejudice 21)
Blackledge v. Allison, 431 U.S. 63 (U.S. 1977) (open-court plea declarations carry a strong presumption of verity 22)
Turner v. State, 919 S.W.2d 346 (Tenn. Crim. App. 1995) (totality-of-the-circumstances test for plea voluntariness 23)