Marvin Kyles v. State of Mississippi
185 So. 3d 408
| Miss. Ct. App. | 2016Background
- Marvin D. Kyles was indicted Aug. 13, 2012 for possession of marijuana and aggravated assault on a law‑enforcement officer; the marijuana count was later dismissed as part of a plea deal.
- On Nov. 30, 2012 Kyles pled guilty to aggravated assault and was sentenced to 10 years in MDOC plus 5 years postrelease supervision and reduced fines.
- On May 3, 2013 Kyles filed a petition treated as a postconviction relief (PCR) petition asserting ineffective assistance of counsel for failing to advise him of a speedy‑trial violation before he pled guilty.
- Kyles alleged more than 295 days elapsed from arrest to plea, arguing a meritorious speedy‑trial claim would have led him not to plead guilty.
- The trial court dismissed the PCR petition without an evidentiary hearing; Kyles appealed, claiming counsel’s failure to pursue the speedy‑trial claim rendered his plea involuntary.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counsel was ineffective for not pursuing a speedy‑trial claim before plea | Kyles: counsel failed to advise him of a likely meritorious speedy‑trial violation (295+ days), so his guilty plea was not voluntary | State: Kyles knowingly and voluntarily waived trial rights at plea hearing; bare allegations insufficient to prove ineffective assistance | Court: Affirmed dismissal — plea was knowingly, voluntarily made and Kyles failed to meet Strickland burden or develop Barker factors beyond delay |
| Whether the delay from arrest to plea violated the Sixth Amendment | Kyles: delay (295+ days) is presumptively prejudicial | State: other Barker factors not addressed; defendant must plead more than conclusory assertions | Court: Delay was presumptively prejudicial, but Kyles offered no analysis of reason for delay, assertion timing, or prejudice, so claim failed |
| Whether a guilty plea waives nonjurisdictional trial rights including speedy trial | Kyles: contends waiver may be invalid if plea induced by ineffective counsel | State: plea colloquy shows express waiver and counsel advised him | Court: A valid, knowing, voluntary plea waives the right; Kyles’s sworn plea colloquy strongly supports voluntariness |
| Whether dismissal without evidentiary hearing was appropriate | Kyles: counsel’s omission required hearing to resolve factual claims | State: allegations were bare and conclusory, not warranting a hearing | Court: Dismissal affirmed — Kyles did not present specific factual detail to require evidentiary development |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective assistance standard)
- Barker v. Wingo, 407 U.S. 514 (sets four‑factor balancing test for speedy‑trial claims)
- Anderson v. State, 577 So. 2d 390 (guilty plea waives nonjurisdictional rights including speedy trial)
- McVeay v. State, 754 So. 2d 486 (delay over eight months is presumptively prejudicial in Mississippi)
- Hill v. State, 60 So. 3d 824 (court colloquy and sworn statements strongly support voluntariness of plea)