Michael Brent Brown v. State, 01-15-00042-CR

Appellant Michael Brent Brown pleaded guilty to felony possession of a controlled substance (amphetamine/Adderall) and admitted two prior enhancement allegations; plea was an open plea to the court.
Judge Hahn accepted the guilty plea and found the enhancements true; later Judge Powell conducted a contested sentencing hearing and imposed life imprisonment, consecutive to a prior 35-year sentence.
Before sentencing, recordings from jail showed Brown discussing fabricating a story and obtaining witnesses/affidavits to claim the pills belonged to others; Brown admitted awareness the pills were in his car.
Brown rejected a State plea offer of 5 years and acknowledged multiple written and oral admonitions that the enhanced range was 25 years to life.
On Motion for New Trial, Brown argued ineffective assistance of counsel: defense counsel allegedly led him to believe the court could treat adulterants/dilutants as reducing the effective quantity, lowering punishment; the trial court denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brown received ineffective assistance of counsel under the Sixth Amendment	Brown: counsel told him the court could argue that adulterants/dilutants reduce the drug quantity and thus reduce punishment range; plea involuntary because he relied on that advice	State: counsel only said the court ‘‘could’’ consider that argument and gave no guarantee; Brown was properly admonished and knew life was possible; no deficient performance or prejudice under Strickland	Motion for new trial denied; appellate posture urges affirmance — court held counsel was effective and Brown knowingly and voluntarily pleaded guilty

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑prong test for ineffective assistance: deficient performance and prejudice)
Bridge v. State, 726 S.W.2d 558 (Tex. Crim. App. 1986) (apply Strickland; review totality of representation, not perfection)
Martinez v. State, 981 S.W.2d 195 (Tex. Crim. App. 1998) (admonishment creates prima facie showing plea was knowing and voluntary; burden shifts to defendant)
Holden v. State, 201 S.W.3d 761 (Tex. Crim. App. 2006) (trial court’s denial of motion for new trial reviewed for abuse of discretion)
Reed v. State, 885 S.W.2d 275 (Tex. App.—Beaumont 1994) (defendant must prove ineffective assistance by preponderance; errorless counsel not required)
McFarland v. State, 845 S.W.2d 824 (Tex. Crim. App. 1992) (courts assess counsel’s performance under standards that do not require perfect representation)