Ralph Ray v. State of Tennessee
E2018-01044-CCA-R3-PC
| Tenn. Crim. App. | Apr 16, 2019Background
- In 2014 Ray was indicted for first-degree felony murder (predicate: aggravated burglary) and second-degree murder; in Sept. 2016 he pleaded guilty to second-degree murder pursuant to a negotiated 25-year, 100% sentence.
- State’s factual recital: Ray forced entry into an apartment, stabbed the victim multiple times, washed the knife, and hid in an attic; an eyewitness identified Ray.
- Ray filed a pro se post-conviction petition and then amended, alleging ineffective assistance (failure to explain charges/lesser-includeds, failure to investigate entry/defenses, coercive plea advice) and nondisclosure.
- Defense counsel pursued mental-health mitigation: multiple evaluations (Hiwassee, Moccasin Bend) and an independent expert (Dr. Montgomery) who opined Ray was legally insane at the time of the offense; prosecution reviewed those records and offered the 25-year plea.
- At the post-conviction hearing the trial court credited defense counsel (and co-counsel/second co-counsel) testimony that elements, defenses (insanity, lesser-includeds), discovery, and plea consequences were discussed; the court discredited Ray’s contrary testimony and denied relief.
Issues
| Issue | Ray’s Argument | State’s Argument | Held |
|---|---|---|---|
| Ineffective assistance — failure to explain felony-murder/aggravated burglary elements | Ray: counsel did not explain foundational elements, so plea uninformed | Counsel: discussed elements, mental-state, lesser-includeds; post-conviction court credited counsel | Denied — testimony credited; no deficient performance shown |
| Ineffective assistance — indictment defect | Ray: indictment defective for alleging two means of aggravated burglary | State: issue raised first on appeal; waived | Denied — appellate review waived |
| Ineffective assistance — investigation of entry (threshold) | Ray: counsel failed to investigate whether he crossed threshold (relevant to aggravated burglary) | State: witness and plea facts supported entry dispute; counsel reviewed scene/discovery | Denied — counsel investigated factual dispute; no ineffectiveness shown |
| Voluntariness/knowledgeability of plea | Ray: plea was unknowing/coerced by ultimatum (25 years or likely life); counsel refused to pursue insanity | State: extensive discussions, mental-health evaluations, plea hearing record show understanding and voluntary choice | Denied — plea found knowing, intelligent, voluntary; claims rejected |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishing two-prong ineffective-assistance test: deficiency and prejudice)
- Hill v. Lockhart, 474 U.S. 52 (application of Strickland to guilty-plea challenges)
- North Carolina v. Alford, 400 U.S. 25 (guilty plea must be voluntary and intelligent)
- Boykin v. Alabama, 395 U.S. 238 (trial court must ensure defendant understands plea consequences)
- Blackledge v. Allison, 431 U.S. 63 (statements under oath at plea hearing carry strong presumption of verity)
- Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (post-conviction factual findings binding unless record preponderates otherwise)
- Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (deference to post-conviction factual findings; review of law de novo)
- Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (failure to prove either Strickland prong is sufficient to deny relief)