Terrance Baker v. State of Mississippi, 217 So. 3d 711

In 2011 Baker was indicted for sale of hydrocodone and sale of marijuana; in 2012 the indictment was amended to charge him as a habitual offender and he pleaded guilty to sale of hydrocodone as a second offender.
At plea Baker received a 15-year sentence with 10 years post-release supervision; plea colloquy and sentencing did not mention a handgun enhancement.
Baker filed a timely PCR in 2015 claiming his guilty plea was involuntary and that counsel provided ineffective assistance (alleging coercion, failure to investigate, lack of communication, and failure to advise of defenses or competency issues).
The trial court dismissed the PCR without an evidentiary hearing, noting Baker presented no affidavits or other supporting evidence and that on the record he had affirmed satisfaction with counsel and voluntariness of the plea.
The Court of Appeals applied the clearly-erroneous standard for factual findings and reviewed legal issues de novo, and affirmed the dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Baker's guilty plea was knowing and voluntary	Baker: plea coerced by counsel (threat of increased sentence), not informed of defenses/elements, sentence based on alleged handgun	State: plea colloquy and record show Baker was advised of rights, elements, consequences; prosecutor's negotiation statements not coercion	Court: Plea was knowing and voluntary; on-the-record statements under oath presumed truthful; no handgun enhancement in plea/sentencing.
Whether Baker received ineffective assistance of counsel	Baker: counsel failed to meaningfully investigate, communicate, advise, or assess competency; coerced plea	State: Baker offered no affidavits/evidence; Baker affirmed satisfaction with counsel at plea; voluntary plea waives most IAC claims absent showing plea involuntariness	Court: Baker failed Strickland prongs—no proof of deficient performance or prejudice; bare assertions insufficient; claim denied.

Jones v. State, 174 So. 3d 902 (Miss. Ct. App. 2015) (standard of review for PCR dismissals)
Williams v. State, 31 So. 3d 69 (Miss. Ct. App. 2010) (requirements for a knowing, voluntary plea)
Thomas v. State, 159 So. 3d 1212 (Miss. Ct. App. 2012) (on-the-record sworn statements carry presumption of veracity)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
Hooghe v. State, 138 So. 3d 240 (Miss. Ct. App. 2014) (prejudice standard in plea context)
Rigdon v. State, 126 So. 3d 931 (Miss. Ct. App. 2013) (voluntary plea waives most IAC claims)
Mayhan v. State, 26 So. 3d 1072 (Miss. Ct. App. 2009) (PCR may be dismissed when petitioner fails to submit affidavits supporting allegations)
Williams v. State, 110 So. 3d 840 (Miss. Ct. App. 2013) (Strickland cited for deficient performance/prejudice standard)