158 So. 3d 330
Miss. Ct. App.2014Background
- Antonio Williams was convicted of murder in 1987 and, as a habitual offender based on two 1982 burglary convictions, was sentenced to life without parole or probation.
- Williams’s direct appeal was affirmed by the Mississippi Supreme Court in 1990.
- He filed multiple post-conviction relief (PCR) attempts: a first application for leave denied in 2003, a second denied in 2006, a PCR motion filed in 2009 dismissed and affirmed on appeal, and a third application for leave denied in 2013.
- In May 2012 Williams filed another motion to vacate (treated as a PCR motion); the circuit court dismissed it as procedurally barred, and Williams appealed the dismissal.
- The Court of Appeals held it (and the circuit court) lacked jurisdiction over the 2012 PCR because Williams never obtained the required prior leave from the Mississippi Supreme Court and his claims were time-barred and barred as successive writs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction to hear 2012 PCR motion | Williams argued the circuit court could consider his May 2012 motion to vacate/supplemental PCR. | State argued Williams failed to obtain prior leave from the Mississippi Supreme Court as required by statute, so the trial court lacked jurisdiction. | Court dismissed appeal for lack of jurisdiction because Williams did not obtain Supreme Court leave. |
| Procedural bars (time-bar / successive-writ) | Williams contended his claims (ineffective assistance re: 1982 pleas; involuntary pleas; speedy trial) merited consideration. | State argued claims were time-barred and barred as successive writs; prior denials and statute precluded relief. | Court agreed claims were time-barred and subject to successive-writ bar; no jurisdiction to entertain them. |
| Ineffective assistance regarding use of 1982 burglary convictions | Williams claimed counsel was ineffective in handling or preserving challenge to prior burglary convictions and pleas. | State maintained Williams failed to show Strickland prejudice and had not preserved or timely presented the claim. | Earlier appellate review found no ineffective assistance; here claim was procedurally barred and not allowed without leave. |
| Voluntariness of 1982 guilty pleas | Williams argued his 1982 pleas were involuntary and therefore prior convictions invalid. | State argued the voluntariness challenge was time-barred and previously rejected. | Court held voluntariness challenge was time-barred and cannot be relitigated without Supreme Court leave. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-part ineffective-assistance-of-counsel standard)
- Williams v. State, 566 So.2d 469 (Miss. 1990) (affirming direct appeal of Williams’s murder conviction)
- Williams v. State, 65 So.3d 319 (Miss. Ct. App. 2011) (addressing Williams’s earlier PCR appeal and finding no ineffective assistance on cited ground)
- Williams v. State, 98 So.3d 484 (Miss. Ct. App. 2012) (noting jurisdictional defect where petitioner failed to obtain prior leave for PCR)