State of Tennessee v. Christopher Clifton, E2015-02307-CCA-R3-CD

Defendant Christopher Clifton pleaded guilty to aggravated assault (Range I); trial court accepted plea and later denied probation, imposing a 4-year sentence at 30%.
Stipulated facts: Clifton returned to a victim's home with a knife, struck the victim and cut him below the ear and under the chin, causing serious injury and hospitalization.
At plea colloquy Clifton stated he understood the plea, rights waived, and was satisfied with counsel; he said seizure medication did not impair his understanding.
After sentencing, Clifton moved to withdraw his plea claiming past stroke, seizures, memory loss, SSI disability, and that these conditions rendered his plea unknowing and involuntary.
Trial counsel testified Clifton had brain trauma/depression/memory issues but did not request or obtain a mental evaluation and believed Clifton understood the proceedings.
Trial court denied withdrawal, finding no proof Clifton lacked competency or that the plea was involuntary; Clifton appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea withdrawal required to correct manifest injustice	State: plea was properly taken and voluntary	Clifton: plea involuntary due to stroke, seizures, memory loss, SSI; court should have sua sponte competency inquiry	Denied — no manifest injustice; record shows plea was knowing and voluntary
Whether trial court should have ordered mental-health evaluation before accepting plea	State: no objective proof required; counsel and defendant assured competency	Clifton: trial court knew of seizure meds/SSI and should have investigated competency	Denied — defendant presented no medical/SSA records or testimony proving incompetency; counsel saw no need for evaluation
Whether Rule 11/Mackey requirements were violated (failure to warn answers could be used for perjury)	State: defendant waived this issue by not raising at trial	Clifton: court failed to inform that plea colloquy answers could be used in perjury prosecution	Waived — issue raised for first time on appeal and not preserved
Whether ineffective assistance of counsel in plea process warranted withdrawal	State: counsel testified plea advice adequate	Clifton: argued counsel should have sought evaluation / advised differently	Implicitly rejected — no showing of ineffective assistance or prejudice to justify withdrawal

State v. Crowe, 168 S.W.3d 731 (Tenn. 2005) (standards for when plea withdrawal required to prevent manifest injustice)
State v. McClintock, 732 S.W.2d 268 (Tenn. 1987) (rules concerning acceptance of guilty pleas and Rule 11 review)
State v. Mackey, 553 S.W.2d 337 (Tenn. 1977) (plea requirements and necessity of informing defendant of rights)
Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (guilty plea must be voluntary and intelligently made)
Blankenship v. State, 858 S.W.2d 897 (Tenn. 1993) (factors for assessing voluntariness and intelligence of plea)
Fontaine v. United States, 526 F.2d 514 (6th Cir. 1975) (affirmative showing that guilty plea was intelligent and voluntary)