Sonia Gonzales v. State of Tennessee, W2015-02496-CCA-R3-PC

Sonia Gonzales was indicted for aggravated burglary (acting in concert) and theft; she pled guilty to aggravated burglary (Class C) for a negotiated four-year sentence; theft charge dismissed.
At plea hearing prosecutor summarized that Gonzales gave a detailed inculpatory statement identifying co‑participants and that victim loss was about $8,500.
Gonzales filed a pro se post‑conviction petition, later amended, alleging ineffective assistance of trial counsel and that her guilty plea was unknowing and involuntary.
Her claims: counsel misadvised her about sentencing exposure (initially misstated Range) and failed to investigate/ litigate issues relating to her mental illness and suppression of her statement.
Trial counsel testified she corrected the sentencing error months before the plea, found Gonzales lucid and competent, filed a minimal suppression motion at Gonzales’s request, and had no basis to expect suppression would succeed.
The post‑conviction court credited counsel, found the plea knowing and voluntary, and denied relief; the Court of Criminal Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel’s sentencing misadvice was deficient and prejudicial	Gonzales: counsel repeatedly and incorrectly advised her about potential exposure, causing her to plead rather than go to trial	State: counsel corrected the error months before plea; no prejudice shown	Court: No relief — misstatement corrected before plea; no prejudice shown
Whether counsel failed to investigate/ litigate mental‑health issues and suppress the statement	Gonzales: counsel failed to investigate her bipolar/schizophrenia history, did not pursue suppression of an involuntary/unenlightened confession	State: counsel observed Gonzales lucid, statement was detailed and reliable, and suppression likely would not have succeeded	Court: No relief — trial court credited counsel; no showing plea was involuntary or counsel ineffective
Whether the guilty plea was knowingly and voluntarily entered	Gonzales: plea was unknowing/involuntary due to counsel’s deficiencies and misinformation	State: plea colloquy and counsel’s testimony show Gonzales understood proceedings and was competent	Court: Plea was knowingly and voluntarily entered; claim denied

Strickland v. Washington, 466 U.S. 668 (1984) (establishes two‑prong ineffective assistance test: deficiency and prejudice)
Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for counsel errors in plea context: reasonable probability petitioner would have gone to trial)
Tidwell v. State, 922 S.W.2d 497 (Tenn. 1996) (trial court findings of fact in post‑conviction proceedings are conclusive unless evidence preponderates otherwise)
Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (deficient performance measured against objective standard of reasonableness under prevailing norms)