STATE OF NEW JERSEY VS. AMIR LEGRANDEÂ (13-10-1875, HUDSON COUNTY AND STATEWIDE), A-4900-14T4

In November 2006 defendant Camile Williams and codefendants were indicted on numerous robberies, conspiracies, assaults, attempts and weapons offenses.
In March 2007 Williams pled guilty to seven armed robbery counts in exchange for the State’s recommendation of an aggregate 15-year sentence with 85% parole ineligibility, and he agreed to testify for the State at codefendants’ trials.
At codefendant Burgess’s trial Williams disavowed his prior police statement implicating Burgess and admitted his own involvement in several robberies; the State later moved to vacate Williams’s plea.
Williams (through different counsel) allowed the State’s motion to vacate; his case proceeded to trial, he was convicted, and received an aggregate 40-year NERA sentence. Direct appeal largely affirmed.
Williams sought PCR, arguing trial counsel (1) misadvised him that his testimony at the Burgess trial would not be admissible at Williams’s trial (which affected his plea decision), and (2) failed to prepare him to testify.
The PCR court found counsel had in fact misadvised about admissibility but denied relief because Williams failed to prove prejudice under Strickland; the court also rejected the inadequate-preparation claim as speculative.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
1) Whether trial counsel’s erroneous advice about admissibility of prior testimony prejudiced Williams’s decision to reject pleas	Counsel’s error did not create a reasonable probability the outcome would differ because Williams had multiple inculpatory statements and the court found his claim not credible	Counsel told Williams his Burgess-trial testimony could not be used unless he testified; Williams says he relied on that and would have accepted a plea, so he was prejudiced	Court affirmed: Even assuming counsel misstated admissibility, Williams failed Strickland prejudice prong — his many confessions and credibility findings negate a reasonable probability of a different plea outcome
2) Whether counsel’s alleged failure to prepare Williams to testify amounted to ineffective assistance	Counsel adequately prepared Williams; Williams’s claim is conclusory and fails to show what testimony would have changed	Counsel did not prepare him for direct/cross and thus counsel’s performance was deficient and prejudicial	Court affirmed: Williams’s bare allegations insufficient; he failed to show how different preparation would have produced a different result

Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-part ineffective assistance test: deficient performance and prejudice)
State v. Fritz, 105 N.J. 42 (1987) (New Jersey’s application of Strickland standard)
State v. Johnson, 42 N.J. 146 (1964) (appellate deference to trial judge credibility findings)