STATE OF NEW JERSEY VS. QUASHON MAYFIELD (11-08-0716, PASSAIC COUNTY AND STATEWIDE)
A-5690-17T4
N.J. Super. Ct. App. Div.Oct 22, 2019Background:
- Defendant Quashon Mayfield (age 16 at the time) chased and shot an unarmed 16-year-old, admitted purpose to kill, and stood over the victim; the incident was captured on video and the victim was permanently paralyzed.
- Mayfield was waived to adult court and pleaded guilty pursuant to a negotiated plea to first-degree attempted murder and second-degree unlawful possession of a handgun; remaining counts were dismissed.
- He received 17 years (NERA) on attempted murder, concurrent 7 years with 3 years parole ineligibility on the gun count.
- At plea hearing Mayfield said the plea was voluntary, satisfied with counsel, and reviewed discovery; he denied trying to reload or shoot again when questioned.
- Mayfield filed a post-conviction relief (PCR) petition nearly six years after judgment, claiming counsel coerced the plea, his youth/mental-health/ignorance excused the late filing, and for the first time asserting the gun accidentally discharged.
- The PCR court (same judge who took the plea and sentenced him) denied relief without an evidentiary hearing; the Appellate Division affirmed.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness: whether PCR filed after 5-year Rule 3:22-12 bar should be excused | The State: Rule 3:22-12 applies; Mayfield was told of time limit at sentencing; youth/ignorance/mental health do not constitute excusable neglect | Mayfield: Youth, mental-health history, and ignorance of law excuse the late filing (excusable neglect) | Denied relief — late filing not excused; judge informed him of the 5-year bar; record shows capacity and no competent evidence of impairment |
| Ineffective assistance of counsel / coerced plea | The State: Counsel properly advised Mayfield of maximum exposure and negotiated a significantly reduced sentence; plea was knowing and voluntary | Mayfield: Counsel forced/coerced him into pleading guilty and failed to preserve trial option; would have gone to trial but for counsel's errors | Denied — no prima facie ineffective assistance; counsel negotiated a favorable plea given strong video evidence; defendant admitted intent to kill; bald assertions insufficient |
| Alleged accidental discharge (claim of factual innocence) | The State: Record and admissions contradict accidental-discharge claim; video corroborates purposeful shooting | Mayfield: The shooting was accidental (raised for first time in PCR) | Denied — claim is a belated, self-serving revision of facts; plea admissions and video evidence negate a colorable innocence claim |
| Evidentiary hearing requirement | The State: No prima facie claim and no material disputed facts requiring a hearing | Mayfield: His allegations required live testimony and factfinding | Denied — no prima facie case of ineffective assistance and existing record resolves the factual issues, so no hearing required |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (test for ineffective assistance of counsel)
- Hill v. Lockhart, 474 U.S. 52 (prejudice standard for plea-stage ineffective assistance)
- State v. Afanador, 151 N.J. 41 (factors and "exceptional circumstances" for relaxing PCR time bar)
- State v. Goodwin, 173 N.J. 583 (time bar should be relaxed only under exceptional circumstances)
- State v. Porter, 216 N.J. 343 (prima facie standard and when an evidentiary hearing is required)
- State v. Blake, 444 N.J. Super. 285 (de novo review when PCR court does not hold evidentiary hearing)
- State v. DiFrisco, 137 N.J. 434 (requirement that defendant show he would have gone to trial but for counsel's errors)
- State v. Merola, 365 N.J. Super. 203 (ignorance of law is not excusable neglect under Rule 3:22-12)