Woods v. State, 71 So. 3d 1241

Woods pled guilty to armed robbery on June 16, 2008 and received a 35-year sentence no parole.
Woods filed a post-conviction relief (PCR) motion January 21, 2010, which the circuit court summarily dismissed.
On appeal, Woods claimed defense counsel misadvised him that the plea would yield at most 10 years.
The Court of Appeals applied standard PCR review: factual findings review for clear error, legal conclusions de novo, and movant bears burden of proof.
The court addressed procedural bar, Strickland (ineffective assistance) claims, voluntariness of the plea, and Eighth Amendment challenges, affirming the circuit court’s dismissal and the sentence as within statutory authority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural bar - were non-raised issues properly barred?	Woods	Woods argued multiple errors; court found only properly raised issues may be considered.	Procedural bar upheld; only properly raised issues considered.
Ineffective assistance of counsel - sufficiency of showings?	Woods	No deficient performance proven; actions within reasonable conduct.	Insufficient showing of deficient performance or prejudice.
Voluntariness of guilty plea	Woods	Plea informed by court; transcript shows understanding of sentence and lack of parole.	Plea voluntary based on in-court assurances and acknowledgments.
Eighth Amendment disproportionality	Woods	Sentence within statutory range; not grossly disproportionate.	No cruel-and-unusual punishment found; within range.

Williams v. State, 872 So. 2d 711 (Miss. Ct. App. 2004) (PCR standards and de novo/review principles)
Staggs v. State, 960 So. 2d 563 (Miss. Ct. App. 2007) (summary dismissal when no relief shown)
Robinson v. State, 19 So. 3d 140 (Miss. Ct. App. 2009) (dependency on procedural viability of claims)
Hill v. State, 60 So. 3d 824 (Miss. Ct. App. 2011) (voluntariness framework for guilty pleas)
Alexander v. State, 605 So. 2d 1170 (Miss. 1992) (plea must be voluntary with knowledge of charges and penalties)