McGuyton v. State
298 Ga. 351
Ga.2016Background
- Appellant James E. McGuyton, Jr. faced murder and weapons charges arising from the November 22, 2012 killing of Kenneth Seek, Jr.; a recidivist notice exposed him to life without parole.
- On the eve of trial McGuyton entered Alford pleas to murder and possession of a firearm by a convicted felon; the State withdrew the recidivist notice and McGuyton received life with parole eligibility after 30 years.
- The State proffered strong evidence: McGuyton’s recorded statement admitting he shot Seek twice, recovery of the murder weapon on his person, spent cartridges found at the co-indictee’s residence, and corroborating statements from co-indictee Rondoe Hutson.
- Shortly before trial McGuyton spoke with an investigator (friend of his sister) and his sister in jail; that meeting preceded his decision to plead but counsel negotiated the plea terms with the prosecutor.
- Ten days after sentencing McGuyton moved pro se to withdraw his pleas, alleging involuntariness, coercion, and ineffective assistance of plea counsel; the trial court denied the motion and the Georgia Supreme Court affirmed.
Issues
| Issue | McGuyton's Argument | State's Argument | Held |
|---|---|---|---|
| Whether an Alford plea requires the defendant to expressly acknowledge the sufficiency of the State’s evidence | McGuyton: Trial court erred because he did not admit evidence was sufficient | State: Alford permits plea so long as defendant intelligently chooses plea and record shows strong evidence of guilt | Court: No. Acknowledgment of sufficiency is not required; Alford plea proper where record shows strong evidence of guilt and plea was voluntary |
| Whether plea was coerced by jail visit with investigator and sister | McGuyton: Visit was "surreptitious" and coerced him into pleading | State: Visit was approved by prosecutor and defense counsel; no improper plea negotiations occurred there | Court: No coercion shown; trial court’s credibility findings upheld |
| Whether plea counsel was ineffective for permitting investigator/sister contact and for negotiation outside counsel | McGuyton: Counsel deficient for allowing outside contact and negotiation absent counsel | State: Negotiations were between plea counsel and prosecutor; meeting did not involve improper questioning | Court: No deficiency or prejudice shown; plea counsel’s performance adequate |
| Whether plea counsel was ineffective for failing to object to prosecutor’s inaccurate ballistic statement | McGuyton: Counsel should have objected to prosecutor’s statement that bullet was a "100 percent" match | State: Inaccuracy was minor; overwhelming evidence (including confession) supported factual basis | Court: No prejudice under Strickland/Hill; plea would have been accepted despite the error |
Key Cases Cited
- North Carolina v. Alford, 400 U.S. 25 (1970) (defendant may plead guilty while maintaining innocence if plea is voluntary and record shows strong evidence of guilt)
- Hill v. Lockhart, 474 U.S. 52 (1985) (Strickland standard applies to ineffective-assistance claims in plea context)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)
- Bell v. State, 294 Ga. 5 (2013) (post-sentencing plea withdrawal permitted only to correct manifest injustice)
- McKiernan v. State, 288 Ga. 140 (2010) (upholding plea entered to avoid harsher sentence and to spare family from trial)