Mancia v. State
2015 Ark. 115
| Ark. | 2015Background
- Mancia pleaded guilty to rape on March 7, 2008 and was sentenced to life imprisonment.
- He filed a Rule 37.1 postconviction petition on July 19, 2010; the circuit court denied it on February 7, 2011.
- Mancia appealed the denial; there were multiple appellate and procedural steps, including per curiam dispositions and a committee sanction against his counsel.
- Mancia asserted eight grounds of ineffective assistance of counsel and related postconviction issues, plus a claim regarding lack of an evidentiary hearing.
- The supreme court affirmed the circuit court’s denial, applying Strickland standards, addressed translator and understanding issues, denied Martinez/Trevino remand, and denied appointment of new counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance due to intoxicated counsel | Mancia claims counsel was intoxicated and sought relief | State contends record shows no impairment | Claim denied; no hearing required |
| Failure to investigate victim’s statement before plea | Counsel’s failure to investigate would have changed plea | No showing that investigation would change outcome | Claim denied; no prejudice shown |
| Failure to investigate pre-plea statements and move to suppress | Counsel failed to challenge pre-plea statements due to language limits | Record shows comprehension and no need for suppression | Claim denied; no prejudice shown |
| Misadvising minimum sentence | Counsel gave incorrect minimum sentence (10 years) | Record shows correct minimum (25 years) and defendant understood it | No prejudice; plea knowingly entered |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong standard for ineffective assistance of counsel)
- Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (prejudice standard for guilty-plea ineffectiveness claims)
- WILLIAMS v. STATE, 369 Ark. 104, 251 S.W.3d 290 (Ark. 2007) (Strickland standard applied to Arkansas postconviction claims)
- Buchheit v. State, 339 Ark. 481, 6 S.W.3d 109 (Ark. 1999) (prejudice required for guilty-plea ineffective claims)
- Olivarez v. State, 2012 Ark. 24 (Ark. 2012) (guilty-plea prejudice standard under Strickland)