Timothy Richard Singleton v. State of Tennessee, M2015-02319-CCA-R3-PC

Background

Timothy R. Singleton was indicted for aggravated robbery and pleaded guilty on August 15, 2013, to an 8-year sentence (85% service), with the trial court recommending placement at the Lois M. DeBerry Special Needs Facility.
Singleton has a documented history of mental-health issues (bipolar I, major depressive disorder, prior hospitalizations, medication) and was taking antipsychotic medication (Risperdal) at the time of the plea.
Defense counsel arranged a forensic evaluation at Vanderbilt; the evaluator concluded Singleton was competent to stand trial and that an insanity defense was not supported.
At the plea hearing Singleton stated he understood the plea, that medication was not affecting his understanding, and that he was satisfied with counsel; the court accepted the plea after finding it voluntary and factually supported.
Singleton filed a post-conviction petition arguing (1) the plea was not knowing/voluntary because of his mental illness, (2) trial counsel was ineffective for not adequately investigating/using his mental-health history to secure a better plea or a finding of incompetence/insanity, and (3) counsel was ineffective for not filing a motion to suppress his custodial statement (he claimed intoxication at the time).
The post-conviction court denied relief; the Court of Criminal Appeals affirmed, finding the plea knowingly and voluntarily entered and counsel’s performance constitutionally adequate.

Issues

Issue	Plaintiff's Argument (Singleton)	Defendant's Argument (State)	Held
Whether the guilty plea was knowing and voluntary given Singleton's mental illness and medication	Mental illness/medication impaired his understanding; plea was not intelligent or voluntary	Singleton affirmed at plea that medication did not affect understanding; Vanderbilt competency finding and plea colloquy show voluntariness	Plea was knowing, intelligent, and voluntary; affirmed
Whether trial counsel was ineffective for failing to further investigate/use mental-health history to obtain a better outcome	Counsel failed to obtain medical records, properly evaluate mental-health mitigation, or pursue incompetence/insanity defenses	Counsel ordered forensic evaluation, reviewed results, discussed risks and plea options; evaluation found competency and no basis for insanity	No deficient performance or prejudice; counsel acted reasonably and Singleton accepted plea after advice
Whether counsel was ineffective for not moving to suppress Singleton’s statement to police (alleged intoxication)	Statement involuntary due to alcohol/narcotics; counsel should have filed suppression motion	No evidence presented that a suppression motion would have succeeded; counsel reviewed the recorded statement and noted no problems	Singleton failed to show motion would have been granted or that he was prejudiced; no relief
Whether post-conviction record supported relief given trial court’s factual findings and credibility assessments	Singleton challenges credibility of plea statements and counsel’s actions	Court relies on plea colloquy, Vanderbilt report, and trial counsel testimony	Trial court’s factual findings not clearly erroneous; appellate court defers and affirms denial

Key Cases Cited

Boykin v. Alabama, 395 U.S. 238 (affirmative showing plea voluntary is required)
Strickland v. Washington, 466 U.S. 668 (ineffective-assistance standard: deficient performance and prejudice)
Hill v. Lockhart, 474 U.S. 52 (prejudice in plea context: reasonable probability defendant would have insisted on trial)
State v. Pettus, 986 S.W.2d 540 (Tenn. 1999) (Tennessee standards for knowing and voluntary plea)
State v. Mackey, 553 S.W.2d 337 (Tenn. 1977) (defendant must be aware of significant consequences of plea)
Dellinger v. State, 279 S.W.3d 282 (Tenn. 2009) (standards for post-conviction review and factual findings)
Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (ineffective-assistance principles in Tennessee)