Seth Clayton Francis Crawford v. State of Minnesota
A16-0812
| Minn. Ct. App. | Feb 6, 2017Background
- Appellant Seth Crawford, arrested after a knife-point robbery, was charged with two counts of first-degree aggravated robbery and pled guilty via a Norgaard plea to both counts with a cap of 58 months, allowed to argue for a dispositional departure.
- At plea hearing Crawford acknowledged adequate time with counsel, understanding of the plea petition, and that he had been advised of the facts.
- At sentencing counsel sought a dispositional departure; the court imposed 58 months’ imprisonment.
- Crawford moved for postconviction relief claiming ineffective assistance of counsel, alleging poor investigation/communication, incorrect guideline advice, an assurance of probation (or short county time then treatment), and inadequate support for a durational departure.
- The postconviction court credited trial counsel’s testimony, found Crawford’s testimony not credible and concluded Crawford failed to show that, but for counsel’s errors, he would have proceeded to trial; the Court of Appeals affirmed.
Issues
| Issue | Crawford’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether counsel provided ineffective assistance in advising and obtaining the guilty plea | Counsel misinformed him on guidelines, failed to investigate/communicate, and promised probation/treatment, so plea was induced | Counsel acted reasonably; any errors did not prejudice Crawford because he would not have gone to trial | Denied — appellant failed to show prejudice under Strickland; plea withdrawal not warranted |
| Whether counsel promised a probationary sentence (guarantee) | Counsel guaranteed short county time then treatment or probation | Counsel only promised to request probation/departure and explicitly could not guarantee sentence; plea paperwork and plea colloquy contradicted a guarantee | Denied — postconviction court credited counsel; no unqualified promise found |
| Whether incorrect guideline math (106 vs. 126 months) constituted ineffective assistance | Counsel’s misstatement about cumulative guideline exposure shows untrustworthy performance | Even accepting the error, Crawford did not show the 20‑month difference would have changed his decision to plead | Denied — no showing of reasonable probability he would reject plea absent the error |
| Whether lack of investigation/communication or weak departure advocacy prejudiced plea decision | More investigation/communication or stronger departure argument would have led Crawford to proceed to trial | Crawford offered no evidence these would have changed his decision; he affirmed adequate consultation at plea | Denied — no evidence that counsel’s alleged deficiencies altered Crawford’s choice to plead |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishing two‑prong ineffective assistance test)
- State v. Ecker, 524 N.W.2d 712 (Minn.) (post‑plea ineffective‑assistance claims require showing one would not have pleaded guilty but for counsel’s errors)
- State v. Trott, 338 N.W.2d 248 (Minn.) (an unqualified promise of probation can warrant withdrawal of plea)
- Hawes v. State, 826 N.W.2d 775 (Minn.) (standard of review for postconviction mixed questions of law and fact)
- Opsahl v. State, 710 N.W.2d 776 (Minn.) (deference to postconviction court credibility findings)