Terrance O. Johnson v. State of Mississippi
2016-CP-00751-COA
| Miss. Ct. App. | Jun 6, 2017Background
- Terrance O. Johnson pleaded guilty on October 22, 2012, to two counts of sale of cocaine (one within 1,500 feet of a school); judgment entered October 24, 2012.
- He received a total sentence of 60 years, with 30 years to serve and five years postrelease supervision.
- Johnson filed a pro se motion for postconviction relief (PCR) on May 2, 2016, asserting his plea was involuntary, his sentence illegal, and trial counsel ineffective; the trial court denied the PCR.
- On appeal Johnson’s sole issue was that he was mentally incompetent to enter the guilty plea due to bipolar disorder and schizophrenia and medication use.
- At the plea hearing Johnson acknowledged his diagnoses and medications but stated they did not affect his understanding; trial counsel affirmed belief in Johnson’s competency and did not request a mental evaluation.
- The trial court found the plea voluntary based on its observations, Johnson’s answers, and counsel’s opinion; this appeal challenges that competency determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Johnson was incompetent to enter a guilty plea and whether the trial court should have ordered a mental evaluation | Johnson: mental-health diagnoses and medications rendered him incompetent and his plea involuntary | State: PCR was time-barred; regardless, record shows Johnson understood proceedings, admitted guilt, and counsel believed him competent | Court affirmed denial of PCR: no reasonable ground existed to doubt competency; plea accepted as voluntary |
Key Cases Cited
- Hughes v. State, 106 So. 3d 836 (Miss. Ct. App. 2012) (standard of review for PCR denials)
- Harden v. State, 59 So. 3d 594 (Miss. 2011) (trial court discretion on competency inquiries; test for reasonable ground to doubt competency)
- Goff v. State, 14 So. 3d 625 (Miss. 2009) (competency-doubt standard: ability to understand proceedings, appreciate significance, and rationally aid counsel)
- White v. State, 59 So. 3d 633 (Miss. Ct. App. 2011) (statutory time bar for PCR motions)