Stephen M. Haines v. State of Indiana (mem. dec.)
45A03-1611-PC-2620
| Ind. Ct. App. | Jun 28, 2017Background
- In 2010 Stephen Haines pleaded guilty to murder and Class B felony robbery in exchange for dismissal of a felony-murder charge and the State's promise not to seek life without parole; agreed aggregate sentence was 80 years (65 + 15, consecutive).
- The factual stipulation: on June 14, 2009 Haines and three others planned and executed a gas-station robbery; Haines pointed a gun, shot the clerk in the back, the clerk died, and the group stole merchandise.
- Haines later filed a petition for post-conviction relief alleging ineffective assistance of trial counsel (invalid plea advice and misinformation about sentence-reduction credits) and a double-jeopardy violation from being convicted of both murder and robbery.
- The post-conviction court held evidentiary hearings, credited trial counsel testimony that they thoroughly reviewed the plea and sentence consequences with Haines, and found no deficient performance or prejudice.
- The court also held Haines waived a double-jeopardy challenge by accepting the plea; alternatively, under the actual-evidence test his convictions did not violate Indiana’s double-jeopardy clause because robbery was charged as Class B (deadly-weapon) rather than Class A (serious bodily injury).
Issues
| Issue | Haines' Argument | State's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel — plea advice | Counsel failed to fully investigate/explain defenses and consequences, so plea was not knowing/voluntary | Counsel thoroughly reviewed plea, rights, and sentence; court informed Haines at plea hearing | Denied — plea was knowing, intelligent, voluntary; counsel not ineffective |
| Ineffective assistance of counsel — sentence-credit advice | Counsel told Haines he could reduce sentence up to 12 years by programs (prejudice) | Counsel did not promise 12 years; they reviewed statutory credit information (max 4 years) | Denied — no credible evidence counsel misadvised; no prejudice shown |
| Double jeopardy from murder + robbery convictions | Same victim and same conduct; convictions constitute double jeopardy | Waived by plea; alternatively robbery as Class B (deadly weapon) has independent elements from murder | Denied — claim waived by plea; alternatively actual-evidence test not met; convictions valid |
| Claim of coercion into plea | Counsel coerced Haines by implying risk of life without parole | No record evidence of coercion; Haines accepted negotiated term to avoid risk | Denied — no evidence of coercion |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance of counsel)
- Richardson v. State, 717 N.E.2d 32 (Ind. 1999) (Indiana same-offense test: statutory-elements and actual-evidence analyses)
- Gross v. State, 769 N.E.2d 1136 (Ind. 2002) (when same act supports Class A robbery and murder, double jeopardy can require reducing robbery)
- Games v. State, 743 N.E.2d 1132 (Ind. 2001) (plea agreement waiver precludes later double-jeopardy challenge)
- Grinstead v. State, 845 N.E.2d 1027 (Ind. 2006) (application of Strickland in Indiana)