Jason Lee Holley v. State of Tennessee
M2017-00510-CCA-R3-PC
| Tenn. Crim. App. | Nov 9, 2017Background
- Jason Lee Holley was indicted for possession of ≥.5 grams of cocaine with intent to sell and related charges; he pled guilty to the Class B felony possession count in exchange for dismissal of remaining counts and a 12-year sentence (12 months day-for-day, 11 years on Community Corrections), consecutive to another plea in a related case.
- Factual basis: police observed a traffic violation, located an abandoned white Chrysler, saw Holley running near the vehicle, found scales and ~21.4 grams of cocaine near where he ran, and Holley had vehicle keys and cash on his person; Holley admitted running because he lacked a license.
- After pleading, Holley filed a pro se post-conviction petition alleging his plea was involuntary and counsel ineffective for failing to file a suppression motion and for undisclosed fingerprint evidence; counsel was appointed and an amended petition was filed.
- At the post-conviction hearing Holley testified counsel promised a suppression motion but did not file it; he pleaded guilty primarily to get out of jail and later received a lab report allegedly showing fingerprints did not match.
- Trial counsel testified she met with Holley multiple times, was drafting a suppression motion while negotiating a plea, informed Holley she would withdraw (taking a judgeship), and discussed the plea and alternatives; the trial court accepted the plea after a canvass.
- The post-conviction court accredited counsel’s testimony, found no ineffective assistance, concluded any suppression motion likely would have failed (police had reasonable suspicion/probable cause), and held Holley’s plea was knowing and voluntary; this ruling was affirmed on appeal.
Issues
| Issue | Holley’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether counsel was ineffective for failing to file a motion to suppress | Counsel promised but did not file suppression motion; had counsel filed it Holley would not have pled | Counsel prepared a suppression motion, negotiated a plea, and counsel’s conduct was reasonable; Holley wanted to get out of jail | Denied — court credited counsel, found no deficient performance and no prejudice; suppression likely would have failed |
| Whether Holley’s guilty plea was knowing and voluntary | Plea was coerced by counsel’s failure to pursue suppression, so plea was unknowing/unintelligent | Plea colloquy shows Holley was informed, clear-minded, and chose plea to get out of jail; valid waiver of rights | Denied — plea was knowing and voluntary based on plea colloquy and trial/post-conviction testimony |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective assistance test)
- Hill v. Lockhart, 474 U.S. 52 (prejudice standard for counsel error in guilty‑plea context)
- Boykin v. Alabama, 395 U.S. 238 (trial court must canvass defendant to ensure plea is voluntary)
- Blackledge v. Allison, 431 U.S. 63 (plea colloquy statements carry strong presumption of truth)
- Vaughn v. State, 202 S.W.3d 106 (Tenn. 2006) (petitioner must show suppression motion would have been granted to prove prejudice)
- Burns v. State, 6 S.W.3d 453 (Tenn. 1999) (deference to tactical decisions of counsel when adequately prepared)
- Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (post‑conviction fact‑finding deference)
- Momon v. State, 18 S.W.3d 152 (Tenn. 1999) (burden of proof in post‑conviction proceedings)