Lynn K.C. Sines v. State of Indiana (mem. dec.)
91A02-1601-PC-113
| Ind. Ct. App. | Oct 18, 2016Background
- Sines, pro se, appeals the denial of his post-conviction relief petition in Indiana.
- In 2012, at a party hosted by Robert Mitchell, Sines allegedly had sexual intercourse with Mitchell’s 15-year-old sister A.M., who reported being assaulted; Mitchell confronted Sines and a fight ensued.
- Sines admitted at the time to sexual intercourse with A.M. and entered a plea agreement with a 10-year cap on his sentence; the court accepted the guilty plea.
- Sines was sentenced to ten years in the Department of Correction, to run consecutively to other sentences, and multiple motions to modify the sentence were denied or not successful through 2016.
- Sines filed a September 2014 petition for post-conviction relief, asserting ineffective assistance of counsel, including failure to investigate threats that allegedly coerced the plea, failure to present DNA evidence, an alibi witness, and challenges to the medical evidence; an evidentiary hearing was held in September 2015; the post-conviction court denied relief and found the plea voluntary; the Court of Appeals affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of trial counsel | Sines claims counsel failed to investigate threats and other evidence. | Record shows counsel’s performance was reasonable and evidence was overwhelming against Sines. | No reversible error; no deficient performance or prejudice shown. |
| Voluntariness of the guilty plea | Threats at gunpoint coerced the plea. | Plea was made knowingly and voluntarily after proper questioning. | Plea knowingly and voluntarily made; affirmed. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (Supreme Court 1984) (establishes two-prong test for ineffective assistance of counsel; prejudice required)
- Johnson v. State, 832 N.E.2d 985 (Ind. Ct. App. 2005) (two-prong standard; deference to trial strategy; prejudice may be shown separately)
- Overstreet v. State, 877 N.E.2d 144 (Ind. 2007) (standard for reviewing post-conviction findings of fact; deferential review to factual determinations)
- Segura v. State, 749 N.E.2d 496 (Ind. 2001) (prejudice prong for ineffective assistance when no viable defense or likelihood of success at trial)
- Richardson v. State, 800 N.E.2d 639 (Ind. Ct. App. 2003) (voluntariness requirements for accepting guilty pleas; court must ensure plea is voluntary)