Steffon Hodges v. State of Tennessee
W2016-00895-CCA-R3-PC
| Tenn. Crim. App. | May 16, 2017Background
- Hodges was tried for aggravated robbery; the jury hung and a mistrial was declared. On the same day he pled guilty to attempted aggravated robbery as a negotiated plea.
- He pled as a Range II offender (pleading outside Range I) and received an effective 10-year sentence with 35% release eligibility.
- At the plea hearing the court and defense counsel explained rights to be waived, that he was pleading outside his range, and that he retained the right to another jury trial; Hodges affirmed understanding and signed the plea.
- Hodges filed a pro se post-conviction petition alleging ineffective assistance of counsel and that his plea was involuntary/unknowing (claimed he was misled about range, parole eligibility, and options after the hung jury).
- At the post-conviction hearing, trial counsel testified he negotiated the plea after the hung jury, explained constitutional rights, parole/eligibility differences, and that Hodges knowingly accepted the plea. The trial court credited counsel’s testimony and denied relief.
- The Court of Criminal Appeals affirmed, holding Hodges failed to prove by clear and convincing evidence that counsel was deficient or that his plea was involuntary.
Issues
| Issue | Hodges' Argument | State's Argument | Held |
|---|---|---|---|
| Whether counsel failed to explain consequences/options after hung jury | Counsel didn’t advise or explain post-mistrial options; Hodges didn’t know he had a right to another trial | Counsel informed Hodges of rights and options; Hodges chose the plea | Denied — court credited counsel and plea transcript showing Hodges knew his rights |
| Whether Hodges was misled into pleading outside his sentencing range | Hodges was "misled" into pleading as Range II instead of Range I and didn’t understand why | Plea form, counsel, and court informed Hodges he was pleading outside his range; Hodges signed and acknowledged this | Denied — record shows Hodges was informed and understood pleading outside range |
| Whether plea was involuntary due to fear/ignorance or poor advice on parole eligibility | Plea resulted from fear, ignorance, and failure to explain parole eligibility/timing | Court and counsel explained parole eligibility and consequences; Hodges sought a better deal after custody | Denied — plea was knowing, voluntary, and intelligent; Hodges failed to show prejudice or deficient performance |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes ineffective assistance standard)
- Hill v. Lockhart, 474 U.S. 52 (prejudice standard for guilty-plea ineffective-assistance claims)
- Vaughn v. State, 202 S.W.3d 106 (deference to post-conviction factual findings; review standards)
- Mackey v. State, 553 S.W.2d 337 (plea must be knowing, voluntary, intelligent)
- Boykin v. Alabama, 395 U.S. 238 (requirements for voluntariness of guilty pleas)