Rachel L. Calhoun v. State of Tennessee
E2016-00858-CCA-R3-PC
| Tenn. Crim. App. | Feb 28, 2017Background
- Rachel L. Calhoun pled guilty to two counts of first-degree murder (merged premeditated and felony murder), especially aggravated robbery, identity theft, and fraudulent use of a credit card; effective sentence: life imprisonment concurrent.
- Stipulated facts: Calhoun admitted attacking and strangling the victim, taking money and credit cards, and using them at ATMs and stores; multiple recorded statements were admitted at plea.
- A latent palm print later was identified by the TBI as Calhoun’s and became the key physical evidence linking her to the scene.
- Calhoun sought post-conviction relief claiming (1) ineffective assistance of counsel for failing to obtain independent testing of the palm print and for allegedly failing to advise her that the State would not seek the death penalty, and (2) that her guilty plea was involuntary due to medical/mental issues and coercion.
- Trial counsel met repeatedly with Calhoun, obtained two court-funded medical experts who did not support a mental‑defense, consulted (by phone) with a latent‑print expert who declined to testify without stronger grounds to challenge the TBI identification, and informed Calhoun that the State would not seek death.
- The post-conviction court credited counsel, found Calhoun not credible, and denied relief; the Court of Criminal Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counsel was ineffective for not obtaining independent testing of the palm print | Calhoun: initial inconclusive testing should have prompted independent testing; an expert could have undermined the match | State: counsel consulted an expert who declined without a factual basis to challenge the TBI identification; no obligation to "shop" for favorable experts | Court: counsel not deficient; even if deficient, Calhoun failed to show prejudice (no proof independent testing would change plea) |
| Whether counsel was ineffective for failing to inform Calhoun she could not be sentenced to death | Calhoun: she believed death was possible and pled because of that fear | State: counsel informed her and she was present when State announced it would not seek death; counsel never led her to believe death remained an option | Court: counsel was not deficient; Calhoun was on notice death was not being sought |
| Whether the guilty plea was knowing and voluntary | Calhoun: mental/medical impairment, coercion, and misunderstanding of consequences made plea involuntary | State: plea colloquy, counsel’s advice, expert evaluations, and Calhoun’s education/experience show plea was informed | Court: considering Blankenship factors, plea was knowing and voluntary; post-conviction court’s credibility findings supported denial |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two‑part ineffective assistance test of deficiency and prejudice)
- Hill v. Lockhart, 474 U.S. 52 (prejudice standard for ineffective‑assistance claims in guilty‑plea context)
- Burns v. State, 6 S.W.3d 453 (Tenn. 1999) (counsel’s duty to investigate and deference to tactical choices)
- Blankenship v. State, 858 S.W.2d 897 (Tenn. 1993) (factors for assessing voluntariness and intelligence of guilty pleas)
- Grindstaff v. State, 297 S.W.3d 208 (Tenn. 2009) (standard for appellate review of post‑conviction factual findings)