Jeffery W. Dean v. State of Tennessee, M2015-01581-CCA-R3-PC

Petitioner Jeffery W. Dean was convicted of aggravated kidnapping and carjacking after a Walmart encounter; surveillance videos, a police photograph, victim ID, and clothing found at his grandmother’s home tied him to the scene.
At trial the defense stipulated to Dean’s identity and pursued a defense that the victim misunderstood Dean’s intent; Dean testified at trial to support that theory and denied taking the victim’s possessions.
Dean was sentenced as a Range II, multiple offender to concurrent 13-year terms; he sought post-conviction relief alleging ineffective assistance of counsel.
Dean claimed trial counsel was ineffective for (1) failing to explain the State’s evidence and counsel’s trial strategy (including the identity stipulation) and (2) failing to prepare him adequately to testify, which he said led him to reject plea offers he otherwise would have accepted.
The post-conviction court credited trial counsel’s testimony that counsel discussed the evidence and strategy with Dean, advised that identity could not be successfully disputed, and recommended Dean testify to support the misunderstanding defense; the court denied relief.
On appeal this court affirmed, finding Dean failed to prove deficient performance or prejudice under Strickland.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for stipulating to identity without Dean's informed consent	Dean: counsel stipulated identity without explaining consequence; would have accepted plea if he had known	State/Trial counsel: stipulation was strategic because identity was strongly proven; counsel discussed defense and needed Dean to testify	Denied — no deficient performance or prejudice; stipulation was reasonable strategy
Whether counsel failed to prepare Dean to testify	Dean: counsel insisted he testify but did not properly prep him	Trial counsel: he "prepped" Dean, advised truthfulness, avoided scripting to keep credibility	Denied — no inadequate preparation proven
Whether counsel’s advice caused Dean to reject plea offers	Dean: would have accepted a plea if aware of strategy and testimony requirement	Trial counsel: advised on plea offers and risks; Dean repeatedly rejected pleas asserting innocence	Denied — Dean did not prove prejudice or misadvice altered plea decision

Strickland v. Washington, 466 U.S. 668 (Establishes two-prong ineffective assistance test: deficient performance and prejudice)
Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (applies Strickland principles in Tennessee; burden and proof explained)
Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (post-conviction factfinding and credibility determinations are for the trial court)
Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (presumption of correctness for post-conviction factual findings on appeal)
Burns v. State, 6 S.W.3d 453 (Tenn. 1999) (ineffective assistance is mixed question of law and fact)
Baxter v. Rose, 523 S.W.2d 930 (Tenn. 1975) (defines competence standard for counsel)
Irick v. State, 973 S.W.2d 643 (Tenn. Crim. App. 1998) (courts should not second-guess reasonable strategic choices with 20/20 hindsight)
Hellard v. State, 629 S.W.2d 4 (Tenn. 1982) (counsel’s tactical choices are given deference)
Taylor v. State, 814 S.W.2d 374 (Tenn. Crim. App. 1991) (claims of ineffective assistance grounded in trial strategy are generally not grounds for relief)