McBride v. State, 108 So. 3d 977

McBride pleaded guilty to two counts of capital murder and received two consecutive life sentences without parole.
A PCR motion was filed on May 16, 2011 and was dismissed by the circuit court.
McBride was indicted for burglary, two counts of capital murder, and aggravated assault; the plea resolved the capital murder counts with a plea agreement.
As part of the plea, the State agreed not to prosecute burglary and aggravated assault charges.
In his PCR motion, McBride alleged coerced police statements, trial delay, mischarged charges, and ineffective assistance of counsel; the circuit court dismissed these claims.
The Mississippi Supreme Court affirmed the circuit court’s dismissal, holding the claims meritless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness of the guilty pleas	McBride argues pleas were involuntary	Plea was voluntary; court advised rights and consequences	Plea voluntary; issue meritless
Ineffective assistance of counsel	Counsel failed to discuss defense strategies (heat-of-passion)	No affidavits; no proven ineffectiveness; insufficient showing	No merit; Strickland standard not satisfied based on record

Lee v. State, 78 So.3d 330 (Miss.2012) (review of PCR dismissals; standard for clear error vs de novo questions of law)
Foster v. State, 716 So.2d 538 (Miss.1998) (procedural bar for raising issues first on appeal)
Loden v. State, 971 So.2d 548 (Miss.2007) (plea voluntary when advised of charges and rights on the record)
Alexander v. State, 605 So.2d 1170 (Miss.1992) (voluntariness when court explains consequences of plea)
Harris v. State, 806 So.2d 1127 (Miss.2002) (court’s on-record advisement controls voluntariness despite attorney advice)
Hill v. Lockhart, 474 U.S. 52 (1985) (reinforces Strickland standard for guilty-plea outcomes)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)