Karen Farr v. State of Mississippi
238 So. 3d 1177
| Miss. Ct. App. | 2017Background
- Karen Farr was indicted for murder and leaving the scene after striking Ronnie Perry; while on bail she was later charged with aggravated assault and bail was revoked.
- On March 6, 2013 Farr pleaded guilty to manslaughter (lesser included) and to aggravated assault; the State retired the leaving-the-scene charge.
- Sentences: 20 years for manslaughter (none suspended) and 20 years for aggravated assault (15 suspended, 5 to serve, 5 years post-release supervision); sentences to run consecutively.
- Farr filed a pro se PCR motion alleging lack of discovery, coercion into plea, ineffective assistance of counsel, law-enforcement negligence and conflict of interest, and a request for sentence reduction in the interest of justice.
- The trial court denied the PCR motion; Farr appealed. The Court of Appeals affirmed, finding the claims meritless or waived by her guilty plea.
Issues
| Issue | Farr's Argument | State's Argument | Held |
|---|---|---|---|
| Failure to provide discovery | Farr says she never received discovery materials or evidence used against her | A guilty plea waives evidentiary/discovery challenges; Farr offers no authority or showing of prejudice | Dismissed — waived by guilty plea |
| Coercion into guilty plea | Farr claims she was coerced during interrogation, was in shock, and had PTSD/battered-woman syndrome; told she'd get parole in 5 years | Plea petition and hearing show plea was voluntary, no promise of lighter sentence, and plea occurred long after interrogation | Rejected — record shows plea was knowing and voluntary |
| Ineffective assistance of counsel | Counsel misadvised re: MDOC/parole eligibility and failed to raise domestic abuse defense | Voluntary guilty plea waives most ineffective-assistance claims except those affecting voluntariness; Farr produced no affidavits or proof that counsel caused involuntary plea | Rejected — no evidence counsel rendered ineffective as to voluntariness |
| Law enforcement negligence / conflict of interest / interests of justice | Farr contends officers should have arrested victim on warrants; victim’s informant role created conflict; requests sentence reduction for unfairness/lack of evidence | Claims lack merit and, in any event, were waived by guilty plea; Farr cites no legal authority | Rejected — meritless and/or waived |
Key Cases Cited
- Stokes v. State, 199 So. 3d 745 (Miss. Ct. App. 2016) (standard of review for PCR denial)
- Jefferson v. State, 855 So. 2d 1012 (Miss. Ct. App. 2003) (guilty plea waives evidentiary issues)
- Doss v. State, 956 So. 2d 1100 (Miss. Ct. App. 2007) (appellate court not required to address arguments unsupported by authority)
- Thomas v. State, 159 So. 3d 1212 (Miss. Ct. App. 2015) (guilty plea generally waives ineffective-assistance claims except as to voluntariness)
- Hill v. State, 940 So. 2d 972 (Miss. Ct. App. 2006) (inartful briefing may be excused but not where deficiencies are substantial)
- Gatewood v. State, 909 So. 2d 754 (Miss. Ct. App. 2005) (appellate briefing standards)