Joshua Williams v. State of Mississippi
220 So. 3d 996
Miss. Ct. App.2017Background
- Joshua Williams was indicted for capital murder; the State reduced charges and Williams pleaded guilty to manslaughter and armed robbery on July 23, 2013.
- Circuit court sentenced Williams to 20 years (manslaughter) plus a consecutive 10 years (armed robbery), and denied a motion to reconsider.
- Williams filed a postconviction relief (PCR) petition asserting incompetence to plead, ineffective assistance of counsel, and actual innocence of manslaughter; the trial court denied relief.
- The plea colloquy and plea petition contained Williams’s sworn statements that he understood the charges, was not under the influence, was mentally and physically capable, and was satisfied with counsel’s assistance.
- Williams submitted 2004 medical records indicating past schizoaffective disorder and related symptoms, but no evidence showing incompetence or incapacity at the 2013 plea hearing.
- The Court of Appeals reviewed the PCR denial for clear error of fact and de novo review of legal conclusions and affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competency to enter guilty pleas | Williams: history of mental-health issues rendered him incompetent; court should have held competency hearing | State: no objective signs at plea to raise reasonable doubt; plea colloquy and counsel certification showed competency | Court: No hearing required; Williams failed to meet burden to show incompetence |
| Voluntariness/Knowing/Intelligent plea | Williams: prior mental-health treatment made pleas involuntary | State: sworn statements in open court and plea petition show voluntariness and understanding | Court: Pleas were voluntary, knowing, and intelligent; claim lacks merit |
| Ineffective assistance of counsel | Williams: counsel failed to investigate competency and interview key witnesses; would have gone to trial | State: record shows counsel discussed plea, certified competency, and no supporting affidavits/evidence of prejudice | Court: Strickland not satisfied; performance not shown deficient nor prejudicial |
| Actual innocence / factual basis for plea | Williams: asserts he is factually innocent of manslaughter | State: plea colloquy contained admissions and factual basis; court relied on record | Court: Sufficient factual basis existed; claim rejected |
Key Cases Cited
- Smith v. State, 831 So. 2d 590 (Miss. Ct. App.) (competency standard and trial judge's discretion to order competency hearing)
- Vanwey v. State, 55 So. 3d 1133 (Miss. Ct. App.) (movant bears burden to prove lack of competency)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (standard for ineffective assistance of counsel)
- Avery v. State, 179 So. 3d 1182 (Miss. Ct. App.) (ineffective-assistance pleading specificity and affidavits requirement)
- Montalto v. State, 119 So. 3d 1087 (Miss. Ct. App.) (criteria for voluntariness of guilty plea)
- Boyd v. State, 65 So. 3d 358 (Miss. Ct. App.) (standard of review for PCR denial)