Juan Manzano v. State of Indiana
12 N.E.3d 321
| Ind. Ct. App. | 2014Background
- Manzano pleaded guilty in 1997 to Class A felony rape and received a 50-year sentence; his post-conviction relief petition was denied after hearings in 2013.
- He challenges trial and appellate counsel effectiveness, asserting various errors affected sentencing and potential trial outcomes.
- B.M., Manzano’s six-year-old daughter, identified him as the attacker; the record shows extensive injury consistent with penetration.
- During discovery and suppression proceedings, trial counsel moved to suppress statements; DNA and home-search issues were raised but not argued as standalone prejudicial errors.
- Manzano contends the trial court erred in imposing maximum punishment after a guilty plea; appellate counsel allegedly failed to raise mitigating issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of trial counsel in plea and sentencing | Manzano | Manzano | No reversible error; insufficient prejudice shown |
| Voluntary intoxication defense viability | Manzano | Manzano | Voluntary intoxication unlikely; no reasonable probability of acquittal; involuntary intoxication lacking evidence |
| Suppression and discovery-related claims | Manzano | State | Evidence cumulative; no demonstrated prejudice; unlikely acquittal absent plea |
| Ineffective assistance of appellate counsel | Manzano | Manzano | No deficient performance; unraised issues unlikely to yield reversal |
Key Cases Cited
- Timberlake v. State, 753 N.E.2d 591 (Ind. 2001) (standard for ineffective assistance of trial counsel in post-conviction)
- Segura v. State, 749 N.E.2d 496 (Ind. 2001) (role of prejudice in guilty-plea ineffective assistance claims)
- Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (reasonable probability of success at trial as to plea-related prejudice)
- State v. Van Cleave, 674 N.E.2d 1293 (Ind. 1996) (plea decision is largely defendant’s prerogative; require significant prejudice for overturn)
- Sanchez v. State, 749 N.E.2d 509 (Ind. 2001) (voluntary intoxication defense and its limitations)
- Payne v. Brown, 662 F.3d 825 (7th Cir. 2011) (Seventh Circuit view on Segura/ Hill divergence (not binding))