Williams v. State
318 Ga. App. 744
| Ga. Ct. App. | 2012Background
- Williams pleaded guilty to two counts of rape under two indictments involving his stepdaughter and her friend, both minors.
- He received two concurrent life sentences.
- He appealed pro se, challenging the denial of his motion to withdraw his guilty plea.
- He had multiple prior appointed attorneys, but dismissed them and proceeded to trial pro se with counsel appointed for trial.
- The trial court denied the motion to withdraw the guilty plea after a contested hearing, finding the plea voluntary and not coerced.
- The court affirmed the judgment, addressing whether Williams was denied counsel, the voluntariness of the plea, and related issues while noting his pro se brief nonconformity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Williams denied his Sixth Amendment right to counsel at the plea stage? | Williams | Williams waived counsel; no denial occurred | No error; waiver and court did not abuse discretion |
| Was the guilty plea involuntary due to coercion or misrepresentation? | Williams | Plea was knowing and voluntary | Plea knowingly and intelligently entered; no coercion found |
| Was there manifest injustice in denying withdrawal of the plea? | Williams | Withdrawal allowed only to correct manifest injustice | No manifest injustice; trial court did not abuse discretion |
Key Cases Cited
- Salazar v. State, 256 Ga.App. 50 (2002) (appellate brief standards; authority cited for nonconforming briefs)
- Frost v. State, 286 Ga.App. 694 (2007) (manifest injustice standard for withdrawal of plea)
- Hubbard v. State, 301 Ga.App. 388 (2009) (rights waived by plea; knowledge of rights)
- Parks v. McClung, 271 Ga. 795 (1999) (Faretta inquiry not required at plea phase)
- Bowers v. Moore, 266 Ga. 893 (1996) (trial court must ensure understanding of waived rights)