Jason Jeffries v. State of Indiana
2012 Ind. App. LEXIS 208
| Ind. Ct. App. | 2012Background
- Jeffries was charged in FA-029 with a Class A felony possession with intent to deliver/manufacture and other counts; a separate FC-113 case included two habitual offender allegations.
- The State amended FA-029 to add a habitual offender count and sought dismissal of other FA-029 and FC-113 counts under a plea agreement.
- Under the agreement, Jeffries pled guilty to Count I in FA-029 in exchange for dismissal of all FC-113 counts and other FA-029 counts.
- The sentencing agreement anticipated a forty-year sentence and dismissal of the two habitual offender counts; Jeffries could seek a sentence modification.
- Jeffries later moved to withdraw his guilty plea after learning the habitual offender enhancement would apply only to FC-113, not FA-029, and new counsel was appointed; the trial court denied the motion.
- The Court of Appeals affirmed, holding no manifest injustice occurred and denial of withdrawal was not an abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the denial of withdrawal proper given potential manifest injustice from habitual offender misapplication? | Jeffries argues the State threatened habitual offender status to coerce plea. | State could pursue a habitual offender under FC-113, not FA-029, but misapplication did not create injustice. | No abuse; misapplication did not amount to manifest injustice. |
| Did counsel’s failure to recognize the inapplicability of the enhancement prejudice Jeffries? | Ineffective assistance claim due to misadvice. | Counsel’s performance did not prejudice; outcome likely no better at trial. | Ineffective assistance claim fails; no prejudice. |
| Did Jeffries knowingly and voluntarily enter the plea given the plea terms and potential sentences? | Jeffries understood rights, penalties, and dismissal terms. | Knowingly and voluntarily entered plea based on the agreement. | Plea knowingly and voluntary; no basis to set aside. |
Key Cases Cited
- Gillespie v. State, 736 N.E.2d 770 (Ind. Ct. App. 2000) (manifest injustice not shown when counts are dismissed under plea)
- Munger v. State, 420 N.E.2d 1380 (Ind. Ct. App. 1981) (plea induced by promise to forego recidivist proceeding; not illusory)
- Brightman v. State, 758 N.E.2d 41 (Ind. 2001) (presumption in favor of trial court's denial; abuse of discretion standard)
- Segura v. State, 749 N.E.2d 496 (Ind. Ct. App. 2001) (ineffective assistance standard in plea context; prejudice required)
- Coleman v. State, 694 N.E.2d 269 (Ind. 1998) (standard for ineffective assistance of counsel; objective reasonableness and prejudice)