Wilton Frederick Bland v. Karen Pszczolkowski, Warden, 15-0939

Petitioner Wilton F. Bland was indicted in Mineral County (child pornography and related offenses) and Grant County (first-degree sexual assault and sexual abuse by a custodian).
In 2008 Bland entered Alford pleas resolving charges in both counties: multiple convictions in Mineral County and one sexual assault plus ten sexual-abuse counts in Grant County; sentences were largely consecutive within counties and Mineral County sentences were ordered concurrent to Grant County sentences.
Bland later filed pro se petitions for writs of habeas corpus in Mineral and Grant Counties, alleging ineffective assistance of trial counsel and that his guilty pleas were involuntary.
The circuit court appointed counsel, held an omnibus evidentiary hearing on August 4, 2015, and issued a 55-page order on September 1, 2015, denying habeas relief with detailed findings and conclusions.
Bland appealed to the West Virginia Supreme Court of Appeals, which reviewed the record, found no substantial question of law or prejudicial error, adopted the circuit court’s findings, and affirmed the denial of habeas relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was constitutionally ineffective	Bland argued counsel’s performance fell below constitutional standards, denying effective assistance	Warden argued record shows no deficient performance or prejudice sufficient to overturn convictions	Court held Bland failed to show counsel was ineffective; circuit court findings supported denial of relief
Whether Bland’s Alford pleas were involuntary	Bland claimed his guilty pleas were not voluntary/knowing	Warden contended the pleas were knowing and supported by record; Alford plea is permissible when strategic	Court held pleas were voluntary and valid; adopted circuit court’s conclusion denying relief

Mathena v. Haines, 219 W.Va. 417 (2006) (standard of review for habeas corpus appeals)
State ex rel. Franklin v. McBride, 226 W.Va. 375 (2009) (appellate review principles)
North Carolina v. Alford, 400 U.S. 25 (1970) (Alford plea doctrine permitting guilty plea without admission of guilt)
Kennedy v. Frazier, 178 W.Va. 10 (1987) (explaining standards for voluntary Alford pleas)