James Anthony Andrews v. State of Tennessee
E2024-00379-CCA-R3-PC
Tenn. Crim. App.Apr 14, 2025Background
- Petitioner James Anthony Andrews pleaded guilty to two counts of aggravated assault and additional charges in a separate case, receiving a total effective sentence of 10 years (eight years concurrent for aggravated assault, served consecutively to a two-year sentence in another matter).
- The manner of service (probation or incarceration) was left to the trial court’s discretion; the court denied Andrews’s request for probation, ordering incarceration.
- Andrews filed for post-conviction relief, alleging ineffective assistance of trial counsel: specifically, that counsel did not adequately investigate the case and failed to properly explain the plea agreement, rendering the pleas unknowing and involuntary.
- A post-conviction hearing was held at which both Andrews and his counsel testified; no video evidence was produced, nor was it definitively shown that a video even existed.
- The post-conviction court denied relief, finding Andrews's testimony not credible, determining that the plea was knowing and voluntary, and that counsel was not deficient. The appellate court affirmed this decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective Assistance of Counsel | Counsel failed to investigate and disclose plea terms | Counsel acted reasonably, all offers explained | Petitioner failed to show deficiency or prejudice |
| Voluntariness of Guilty Plea | Pleas not entered knowingly or voluntarily | Pleas were knowing and voluntary | Plea was knowing and voluntary; no relief |
| Failure to Secure Exculpatory Evidence | Counsel did not secure or seek video evidence | No proof video existed, no prejudice | No evidence of such a video or of prejudice |
| Adequacy of Appellate Record | — | Record inadequate for meaningful review | Inadequate record; presumption in trial court's favor |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance of counsel claims)
- Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (defines prejudice standard for guilty pleas based on ineffective assistance)
- Baxter v. Rose, 523 S.W.2d 930 (Tenn. 1975) (sets out standard for effective assistance under Tennessee law)
- State v. Taylor, 992 S.W.2d 941 (Tenn. 1999) (petitioner must provide adequate record on appeal)
- Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (failure to prove either Strickland prong is sufficient to deny relief)