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State of Tennessee v. Jimmy Newell
E2015-01913-CCA-R3-CD
| Tenn. Crim. App. | Aug 8, 2017
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Background

  • Defendant Jimmy Newell pled guilty in multiple Bradley County cases at a single hearing under a global plea deal for a total four-year sentence.
  • Newell moved to withdraw his pleas pro se; counsel was appointed and an evidentiary hearing followed, after which the trial court denied withdrawal.
  • Trial counsel testified about pretrial plea negotiations: a three-year offer to wrap all cases, later replaced by a four-year offer encompassing all charges; Newell agreed.
  • Newell testified he believed the deal included community corrections and that he would serve 30% of the sentence, later learning the actual terms differed.
  • Prosecutor testified the original offer was three years to wrap cases; the final offer was four years TDOC-concurrent, with no community corrections.
  • The trial court found the pleas knowingly, voluntarily, and intelligently entered and denied withdrawal, noting credibility determinations and the strength of the State’s case.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Were the pleas knowingly and voluntarily entered? Newell claims involuntary/unknowing pleas. Newell argues lack of understanding and ineffective counsel. No abuse of discretion; pleas were knowingly, voluntarily entered.
Did the trial court substantially comply with Rule 11 demands for guilty pleas? Newell asserts Rule 11 compliance failed because of missing max-penalty advisement. State contends substantial compliance. Court substantially complied; no relief warranted.
Did the court improperly participate in plea negotiations? Newell claims court interfered by pressuring terms. State contends court did not compel offers; only stated discretion on incarceration. No improper interjection; plea negotiations remained prosecutorial domain.
Did any ineffective assistance of counsel or conflict of interest render the plea involuntary? Newell asserts ineffective aid and conflict due to relations between counsel and a State witness. Newell contends conflicts affected representation. No reversible prejudice; no actual conflict established; counsel performance not deficient in plea context.

Key Cases Cited

  • Lane v. State, 316 S.W.3d 555 (Tenn. 2010) (substantial compliance acceptable for Rule 11)
  • Newsome, 778 S.W.2d 34 (Tenn. 1989) (substantial compliance doctrine for plea advisements)
  • Mackey, 553 S.W.2d 337 (Tenn. 1977) (knowingly voluntary plea standard guidance)
  • Howell v. State, 185 S.W.3d 319 (Tenn. 2006) (factors for voluntary plea validity)
  • Turner, 919 S.W.2d 346 (Tenn. Crim. App. 1995) (manifest injustice standard in plea withdrawal)
  • Crowe, 168 S.W.3d 731 (Tenn. 2005) (withdrawal of guilty pleas; ineffective-assistance framework)
  • Hill v. Lockhart, 474 U.S. 52 (1985) (guilty plea must be evaluated under Strickland prejudice standard)
Read the full case

Case Details

Case Name: State of Tennessee v. Jimmy Newell
Court Name: Court of Criminal Appeals of Tennessee
Date Published: Aug 8, 2017
Docket Number: E2015-01913-CCA-R3-CD
Court Abbreviation: Tenn. Crim. App.