Ronald Weaver v. State of Indiana (mem. dec.)
20A03-1601-PC-14
| Ind. Ct. App. | Oct 14, 2016Background
- Police executed a search warrant at Weaver's home; officers found .3 grams of methamphetamine on his wife, pseudoephedrine, a digital scale, receipts for precursors, and a two-liter (Hawaiian Punch) bottle with a hose, valve, sludge, and liquid containing ammonia. Weaver admitted manufacturing methamphetamine and producing 3–6 grams per batch.
- State charged Weaver with Class A felony manufacturing methamphetamine (3+ grams).
- Weaver pleaded guilty in 2012 and received a 40-year sentence with 10 years suspended to probation.
- Weaver filed a pro se post-conviction petition (later amended), arguing his plea was not knowing/voluntary because counsel misled him about likelihood of conviction, and asserting ineffective assistance of counsel for advising the plea.
- The post-conviction court held an evidentiary hearing and denied relief; Weaver appealed, challenging the voluntariness of his plea and counsel’s performance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Weaver’s guilty plea was knowing, voluntary, and intelligent | Weaver: counsel misled him by saying State had enough evidence to convict of Class A (3+ grams) despite only .3 g found on person | State: at plea time law allowed unfinished methamphetamine evidence to count toward weight; Weaver confessed and lab items corroborated manufacture | Court: Plea was knowing/voluntary; counsel did not mislead Weaver |
| Whether trial counsel was ineffective for advising plea | Weaver: counsel’s advice to accept A-felony plea was objectively unreasonable and prejudiced him | State: counsel’s advice was reasonable given confession, corroborating lab evidence, exposure to additional charges, and negotiated benefits (30-year cap on executed time, dismissal/no further charges) | Court: No ineffective assistance; counsel’s performance was reasonable and Weaver failed to show prejudice |
Key Cases Cited
- Fisher v. State, 810 N.E.2d 674 (Ind. 2004) (post-conviction burden and appellate standard)
- Weatherford v. State, 619 N.E.2d 915 (Ind. 1993) (appellate review of post-conviction denial)
- Ben-Yisrayl v. State, 729 N.E.2d 102 (Ind. 2000) (standard for reversing post-conviction findings)
- Traylor v. State, 817 N.E.2d 611 (Ind. Ct. App. 2004) (allowing unfinished methamphetamine weight to count toward enhancement at that time)
- Halsema v. State, 823 N.E.2d 668 (Ind. 2005) (State must present evidence of drug weight for enhancement)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
- Davidson v. State, 763 N.E.2d 441 (Ind. 2002) (applying Strickland in Indiana)
- Grinstead v. State, 845 N.E.2d 1027 (Ind. 2006) (definition of reasonable probability for prejudice)
- Buelna v. State, 20 N.E.3d 137 (Ind. 2015) (clarifying that intermediate mixtures count toward weight only if State shows finished-yield equivalence; cited as later overruling Traylor but not applied here)