Williams v. State
98 So. 3d 1090
| Miss. Ct. App. | 2012Background
- Williams filed a February 2010 PCR asserting speedy-trial violations, ineffective assistance, and withholding of a motion to dismiss.
- He amended in May 2010 alleging involuntary guilty pleas and further ineffective assistance claims, including failure to pursue the speedy-trial issue.
- The circuit court denied PCR in September 2010, noting it had considered the speedy-trial motion and found no basis for ineffective assistance.
- Williams appealed with combined issues: involuntary pleas, ineffective assistance related to pleading and speedy-trial, and speedy-trial violations.
- The Court of Appeals affirmed, applying de novo review to questions of law and upholding procedural bars on his unraised or untimely claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Guilty pleas were voluntary; basing arguments on insufficient factual basis | Williams argues there was no factual basis for his pleas. | State contends the issue wasn’t properly before the court and, procedurally, no basis shown. | Procedurally barred and meritless. |
| Ineffective assistance—plea coercion and speedy-trial failure | Williams claims counsel coerced pleas and failed to pursue speedy-trial rights. | State asserts no prejudice shown and issue not proven. | Procedurally barred and meritless. |
| Speedy-trial rights waived by entering guilty pleas | Williams asserts speedy-trial violations before plea. | State maintains waiver via valid guilty pleas. | Waived; issues lack merit. |
Key Cases Cited
- Brown v. State, 731 So.2d 595 (Miss. 1999) (clear factual findings reviewed for clearly erroneous error; law de novo)
- Faye v. State, 859 So.2d 393 (Miss.Ct.App. 2003) (amendment deadline and URCCC 2.04 guidance on motions to amend)
- URCCC 2.04, - (-) (duty to pursue motion to hearing and decision)
- Anderson v. State, 577 So.2d 390 (Miss. 1991) (speedy-trial waiver by guilty plea)