Ronnie L. Boyd v. State of Mississippi, 190 So. 3d 865

Ronnie L. Boyd was indicted on bribery, tampering with physical evidence, and possession of a controlled substance; the State moved to amend to add a habitual-offender charge.
On January 28, 2009, Boyd pleaded guilty to bribery as a habitual offender; other counts were retired. He was sentenced to 10 years without parole/probation/early release/good time and fined $5,000.
Boyd filed a post-conviction relief (PCR) motion arguing his guilty plea was involuntary due to long‑term health problems (a 1999 car wreck and a 2003 heat stroke) and that trial counsel was ineffective for failing to investigate/present those health issues and for allegedly failing to convey a plea offer.
At an evidentiary hearing Boyd presented medical records and his wife’s affidavit; Boyd’s plea petition and counsel’s certificate both stated his mental and physical health were satisfactory and that he was satisfied with counsel.
The trial court denied PCR, finding Boyd offered no evidence his health rendered him incompetent to plead and that counsel’s performance was not deficient nor prejudicial; the Court of Appeals affirmed.

Issue	Plaintiff's Argument (Boyd)	Defendant's Argument (State / Trial Court)	Held
Whether plea was knowing/voluntary	Boyd: Longstanding health problems rendered him incompetent to enter plea	Trial court/State: Plea colloquy, plea petition, and counsel’s certification show Boyd was competent and understood consequences	Affirmed — plea was knowing, voluntary, intelligent
Whether counsel was ineffective for not investigating/presenting health issues	Boyd: Counsel failed to inquire about or present health evidence at plea hearing	State/Court: Counsel asked about health; Boyd answered satisfactory; no deficient performance or prejudice shown	Affirmed — no ineffective assistance
Whether counsel failed to convey a plea offer	Boyd: Counsel did not inform him of a pretrial plea offer	State/Court: Issue not raised below (procedurally barred); counsel testified she discussed an offer and Boyd declined; later offer became the plea	Procedurally barred and, on merits, without proof — claim fails
Whether Boyd would have proceeded to trial but for counsel’s errors	Boyd: Would not have pled guilty if properly advised/informed	State/Court: Boyd’s sworn statements and hearing testimony contradict this; no reasonable probability of different result shown	Affirmed — no prejudice (Strickland standard not met)

Strickland v. Washington, 466 U.S. 668 (1984) (two‑part test for ineffective assistance: deficient performance and prejudice)