Rice v. State, 301 Ga. 746

In April 2010, Rice reported being robbed by James Abney Jr.; later that day Rice borrowed a gun, drove with Stanley Dominy, found Abney, and fatally shot him in the head. Rice initially blamed Dominy for the shooting.
Rice and Dominy were indicted for malice murder, felony murder, and possession of a firearm during a crime; Rice was set for trial alone with multiple witnesses expected to testify against him.
Rice’s original counsel was removed shortly before the January 2011 trial for a conflict; Ann Parman was appointed in late February and had limited time to prepare before the March trial date.
On March 8, 2011, after telling the court he had resolved concerns about Parman, Rice pled guilty to felony murder pursuant to a joint recommendation and received life with parole; other charges were nolle prossed.
Rice soon sought to withdraw the plea, claiming duress (forced to plead because counsel lacked time) and ineffective assistance for inadequate preparation; the trial court held a hearing, denied withdrawal, later granted an out-of-time appeal, and the appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rice’s plea was involuntary/under duress because Parman lacked preparation time	Rice: Plea was coerced by choice between pleading and going to trial with unprepared counsel	State: Rice represented he had resolved concerns, waived rights, and both lawyers advised him the State’s case was strong	Court: Plea was voluntary; trial court did not err in denying withdrawal
Whether Rice received ineffective assistance of counsel from Parman due to limited preparation	Rice: Parman’s limited time/preparation was objectively deficient and prejudiced his decision to plead	State: Parman met multiple times, reviewed prior counsel’s file and State’s file, consulted prosecutors and opposing counsel; Rice cannot specify how additional prep would help	Court: No deficient performance shown and no prejudice; ineffective-assistance claim fails

Mims v. State, 299 Ga. 578 (court may rely on plea colloquy and counsel’s assurances to find plea voluntary)
Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective assistance test: deficient performance and prejudice)
Kimmelman v. Morrison, 477 U.S. 365 (counsel’s performance assessed under objective reasonableness; heavy burden on defendant)
Hill v. Lockhart, 474 U.S. 52 (prejudice in plea context requires reasonable probability defendant would have gone to trial)
Harris v. State, 279 Ga. 304 (no fixed amount of conference time required; defendant must show how additional contact would have helped)