Woods v. State
379 P.3d 1134
Kan. Ct. App.2016Background
- In 2002 Woods was charged with two counts of first-degree murder and aggravated battery for shootings that killed Davonta Mitchell and Antonio Allen; he pleaded guilty to second-degree murder in 2003, stating on the record, "I shot and killed [Davonta] Mitchell."
- Woods later moved to withdraw the plea, alleging counsel misled him about sentence length and that a witness (Kaylen Irby) had recanted; the district court denied the motion after an evidentiary hearing and sentenced him to 258 months. This denial was affirmed on direct appeal (Woods I).
- Woods filed a first K.S.A. 60-1507 motion alleging ineffective assistance for failing to investigate witnesses (Solomon, Irby); the district court denied relief after a hearing and this denial was affirmed on appeal (Woods II).
- Woods filed a second, untimely and successive K.S.A. 60-1507 motion raising (again) ineffective-assistance and newly discovered statements recanting prior incriminating testimony, and asserting a colorable claim of actual innocence to overcome procedural bars.
- The district court summarily denied the second motion as untimely, successive, barred by res judicata, and not showing manifest injustice; the Court of Appeals affirmed, holding a valid, voluntary guilty plea precludes collateral attack on factual innocence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Woods' untimely, successive K.S.A. 60-1507 motion should get an evidentiary hearing based on actual innocence or counsel ineffectiveness | Woods: new witness statements and recantations, plus counsel failures, create a colorable actual innocence claim and show manifest injustice/exceptional circumstances | State: claims are untimely, successive, barred by res judicata and waiver; no manifest injustice; plea was voluntary | Denied — procedural bars apply; summary denial affirmed because a valid guilty plea forecloses collateral attack on factual innocence |
| Whether res judicata/waiver bar re-litigation of prior ineffective-assistance claims | Woods: frames some allegations as newly discovered; contends actual innocence should override res judicata | State: Woods raised same issues previously; prior final rulings bar re-litigation | Held: res judicata and waiver bar relitigation of issues previously decided or abandoned |
| Whether a colorable claim of actual innocence can overcome timeliness and successiveness when conviction followed a voluntary guilty plea | Woods: actual innocence is gateway to overcome procedural bars | State: even if innocence claim exists, a voluntary guilty plea admits the facts and bars collateral challenges to factual guilt | Held: Even a colorable innocence claim cannot collaterally attack a conviction obtained by a valid guilty plea; procedural bars not overcome |
| Whether Woods was entitled to appointed counsel for the 60-1507 motion | Woods: counsel needed because motion raised substantial questions | State: appointment required only if preliminary hearing warranted | Held: No appointment required; summary dismissal proper so no counsel entitlement |
Key Cases Cited
- Hughes v. State, 206 Kan. 515 (Kan. 1971) (guilty plea is admission of truth of charge and material facts)
- Bousley v. United States, 523 U.S. 614 (1998) (voluntary, intelligent guilty plea advised by competent counsel cannot be collaterally attacked on sufficiency grounds)
- Broce v. United States, 488 U.S. 563 (1989) (same principle: valid guilty plea bars collateral attack on factual guilt)
- Mabry v. Johnson, 467 U.S. 504 (1984) (guilty pleas entered with competent counsel foreclose collateral attacks), overruled in part on other grounds by Puckett v. United States
- Drach v. Bruce, 281 Kan. 1058 (Kan. 2006) (res judicata applies to K.S.A. 60-1507 motions for issues resolved on final appellate order)
- Crow v. United States, 397 F.2d 284 (10th Cir. 1968) (guilty plea admits facts and is not subject to collateral attack on factual innocence)