Young v. State, 2015 Ark. 65

Background

Frederick Young III pleaded no-contest to aggravated residential burglary and guilty to aggravated assault and being a felon in possession of a firearm pursuant to a negotiated plea; concurrent sentences totaling 13 years plus a two-year suspended imposition of sentence were imposed.
The State nolle prossed additional counts and agreed to forgo sentencing enhancements as part of the plea deal.
Young signed a plea statement acknowledging understanding of rights, sentencing ranges, and that the pleas were voluntary and not induced by improper promises; in court he stated he was "freely, knowingly, and voluntarily" pleading and admitted guilt.
Young filed a timely Rule 37.1 petition alleging (1) his pleas were not knowing and voluntary because of pressure and inadequate counsel communication, and (2) ineffective assistance of counsel for failure to investigate and to keep him informed.
At the evidentiary hearing, Young testified his lawyer delayed discovery and pressured him to accept a plea; defense presented testimony that counsel had discussed options, met with Young multiple times, and limited early disclosure of discovery for strategic reasons.
The circuit court found Young not credible, rejected his Rule 37 claims, and denied relief; the Supreme Court of Arkansas affirmed, deferring to the circuit court’s credibility findings and applying Strickland/Hill standards for plea-stage ineffective-assistance claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pleas were knowing and voluntary	Young: felt coerced, pressured by counsel and emotions of family; counsel rushed discovery discussion before plea	State: Young signed plea statement, admitted in court plea was voluntary; counsel credibly testified he explained options and was willing to go to trial	Court: Pleas were knowing and voluntary; circuit court credibility finding not clearly erroneous
Whether counsel failed to investigate adequately	Young: investigator identified missing statements, file gaps, possible forensic issues (no casings/bullet holes), recordings not reviewed	State: Presumption of reasonable assistance; Young failed to show what specific additional evidence would have been found or how it would have changed his decision to plead	Court: Failure-to-investigate claim conclusory; no prejudice shown under Hill/Strickland
Whether counsel failed to keep client informed / delayed discovery	Young: counsel did not communicate often and delayed providing discovery until just before plea	State: Counsel met multiple times in jail, had a long pre-plea conference, and strategically limited early discovery to prevent misuse by other inmates	Court: Counsel’s communication was reasonable under the circumstances; not objectively deficient
Whether cumulative errors require relief	Young: combined errors rendered assistance ineffective	State: At least one error must independently satisfy Strickland; no single error met the standard	Court: Cumulative-error claim rejected; no standalone Strickland violation found

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (establishes two-part ineffective-assistance test) (applied to plea context)
Hill v. Lockhart, 474 U.S. 52 (1985) (applies Strickland prejudice prong to challenges to guilty pleas)
Haywood v. State, 288 Ark. 266 (Ark. 1986) (adopting Hill framework for guilty-plea ineffective-assistance claims)
Buchheit v. State, 339 Ark. 481 (discusses prejudice requirement when guilty plea is challenged)
Polivka v. State, 362 S.W.3d 918 (Ark. 2010) (presumption of reasonable assistance; burden on defendant to specify counsel errors and resulting prejudice)
Watson v. State, 444 S.W.3d 835 (Ark. 2014) (defendant must show further investigation would likely have produced material affecting outcome)
Noel v. State, 342 Ark. 35 (Ark. 2000) (rejecting cumulative-error basis for ineffective-assistance claim)
Huddleston v. State, 339 Ark. 266 (Ark. 1999) (same on cumulative-error principle)