Tyner v. State
289 Ga. 592
| Ga. | 2011Background
- Tyner pled guilty in 1984 to malice murder; records show he was advised of two Boykin rights but not the right against self-incrimination.
- The State indicated it would seek the death penalty if the case went to trial; Tyner accepted a life sentence after the plea.
- Tyner later challenged the plea, initiating multiple post-conviction and habeas petitions over the years, including an out-of-time appeal in 2010.
- The State conceded the plea record did not show advisement of the right against self-incrimination, and the Court treats the Boykin issue as central on direct appeal.
- The majority ultimately holds that the guilty plea is invalid due to the lack of proper Boykin advisement, reversing the conviction and remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Tyner's guilty plea is valid under Boykin | Tyner argues lack of self-incrimination advisement invalidates plea | State contends record could support validity or remand for withdrawal with extrinsic evidence | Guilty plea invalid; conviction reversed |
Key Cases Cited
- Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (necessity of knowing and voluntary waiver of Boykin rights in guilty pleas)
- Moore v. State, 285 Ga. 855 (Ga. 2009) (burden on state to prove knowing and voluntary plea)
- King v. State, 270 Ga. 367 (Ga. 1998) (direct-appeal standard for Boykin waiver)
- Bazemore v. State, 273 Ga. 160 (Ga. 2000) (proof of Boykin rights may be proven extrinsically)
- Smith v. State, 287 Ga. 391 (Ga. 2010) (review of guilty-plea errors on direct appeal)
- Goodman v. Davis, 249 Ga. 11 (Ga. 1982) (prior framework on Boykin rights and plea validity)
- Wilson v. Kemp, 288 Ga. 779 (Ga. 2011) (strict formal application of Boykin rights in plea advisement)
- Arnold v. Howerton, 282 Ga. 66 (Ga. 2007) (Boykin waiver considerations in Georgia pipeline cases)
- Nash v. State, 271 Ga. 281 (Ga. 1999) (origin of “three Boykin rights” discussion in Georgia)
- Britt v. Smith, 274 Ga. 611 (Ga. 2001) (limitation on Boykin rights disclosure in plea advisement)