Wright v. State
292 Ga. 825
| Ga. | 2013Background
- Wright pleaded guilty to two counts of malice murder and related charges and was sentenced to life without parole.
- He moved to withdraw his guilty plea, alleging coercion and ineffective assistance of trial counsel.
- The trial court ruled the plea was intelligent, knowing, and voluntary and denied withdrawal.
- On appeal, the Georgia Supreme Court upheld the trial court’s ruling, affirming the conviction and sentence.
- The record showed Wright was 37, literate, sane, and not threatened, with rights adequately explained and waived.
- Counsel testified Wright was advised of likely outcomes; the court credited counsel over Wright’s withdrawal testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the guilty plea voluntary and intelligent? | Wright contends coercion/vulnerability affected voluntariness. | State maintains Wright knowingly waived rights after proper advisement. | Yes; plea voluntary and intelligent. |
| Did trial counsel provide ineffective assistance by failing to properly investigate? | Counsel’s investigation could have uncovered alternative shooters or associates. | Counsel reasonably investigated; no deficient performance. | No; no deficient performance shown. |
Key Cases Cited
- Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (requires knowing, intelligent waiver of rights for a valid plea)
- Loyd v. State, 288 Ga. 481 (Ga. 2011) (record may show plea knowing and voluntary; reliance on extrinsic evidence permissible)
- Walden v. State, 291 Ga. 260 (Ga. 2012) (withdrawal of guilty plea proper only to correct manifest injustice; trial court’s discretion)
- Stinson v. State, 286 Ga. 499 (Ga. 2010) (trial court may credit counsel over defendant’s version of events)
- Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (ineffective assistance in guilty plea context requires reasonable probability of different outcome)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (duty to make reasonable investigations; deference to counsel’s judgments)