Latoya Danielle Patton appeals the denial of her post-conviction relief petition by the Davidson County Criminal Court after pleading guilty to second degree murder, a Class A felony, with a forty-year sentence as part of a negotiated plea agreement. Patton argues that her guilty plea was not entered knowingly and voluntarily due to ineffective assistance of counsel. The court affirms the post-conviction court's judgment.
The factual background indicates that on April 23, 2005, the victim was found dead with multiple stab wounds in his apartment. After initially denying involvement, Patton admitted to killing the victim over a crack cocaine dispute. She detailed the murder, describing how she stabbed him eighteen times with different implements and later retrieved the victim's crack cocaine. Following her guilty plea to second degree murder, which was accepted by the court, she was sentenced outside her statutory range. Subsequently, Patton filed for post-conviction relief, asserting ineffective assistance of counsel.
A hearing took place where both the petitioner and her trial counsel provided testimony. The petitioner, who had a history of drug use and claimed the victim was abusive, stated that trial counsel was the second attorney assigned to her case, beginning his representation several months after it commenced. She disclosed to trial counsel her drug influence at the time of the murder, her abusive relationship with the victim, and her reliance on him for drugs. The petitioner recounted trial counsel's initial belief that she might only be convicted of manslaughter, but later presented her with a plea offer, which she accepted just days before the trial.
She requested a continuance to allow her family more time to hire a different attorney, but the court denied this request. Although she acknowledged understanding the court's explanations during the plea process, she later claimed confusion and a lack of understanding, believing that her guilty plea would allow her time to appeal and potentially retry her case. The petitioner expressed a desire to testify before a jury and felt pressured to accept the plea without adequate representation.
Trial counsel testified that after reviewing evidence, including the petitioner’s police confession—which indicated a motive related to drug use—he concluded that a first-degree murder conviction was likely. He stated he informed the petitioner of this assessment but still assured her that he would advocate for her if she chose to go to trial, though he recommended accepting the plea. On the day the plea was entered, trial counsel reviewed the agreement with her, asserting she showed no signs of confusion regarding the terms or her right to appeal, which he indicated would be her final court appearance.
The petitioner’s parents expressed distress over her acceptance of a plea agreement, while the petitioner indicated during the hearing that she wished to avoid a life sentence. Trial counsel reported effective communication with the petitioner and believed there was no need for a mental evaluation, asserting that she would not be found insane. He enlisted a private investigator to aid in her case. The post-conviction court denied the petitioner relief, prompting a timely appeal.
On appeal, the petitioner argues that the post-conviction court wrongly denied relief based on ineffective assistance of counsel and that her plea was not entered knowingly and voluntarily. She suggests that trial counsel's advice to plead guilty was flawed, particularly since a self-defense argument could have been raised.
The court evaluates whether a guilty plea is voluntary and intelligent, utilizing the totality of circumstances, including the defendant's intelligence, familiarity with criminal proceedings, the quality of counsel's representation, and the advice received regarding charges. Once a plea is entered, claims of ineffective assistance only matter if they affect the plea's voluntariness. To prove ineffective assistance, the petitioner must show that counsel's performance fell below professional standards and that this deficiency resulted in prejudice. Specifically, she must demonstrate a reasonable probability that, had it not been for counsel's errors, she would have rejected the plea and opted for trial.
The petitioner cannot benefit from hindsight, criticize sound trial strategies, or question tactical decisions unless they were made without adequate preparation. The determination of counsel's performance and any resulting prejudice involves both legal and factual considerations.
A trial court's findings of fact in ineffective assistance of counsel claims are reviewed de novo on appeal, with a presumption of correctness unless the evidence suggests otherwise. In contrast, conclusions of law are reviewed purely de novo, without any presumption. The petitioner contends that her counsel provided ineffective assistance by advising her to plead guilty instead of pursuing a self-defense argument. She testified that her counsel initially believed a manslaughter verdict was likely and acknowledged that her lack of prior convictions could support her defense. However, the counsel changed his position after reviewing her police statement, which indicated that she had stabbed the victim under questionable circumstances, such as hiding the knife and asking the victim for a kiss. The post-conviction court credited trial counsel's testimony that he had adequately prepared for the defense, including hiring an investigator and assessing the case's strong evidence against the petitioner. Ultimately, the appellate review found no compelling evidence against the post-conviction court's determination that trial counsel's performance was not deficient, as the facts did not support a self-defense theory.
Trial counsel's representation of the petitioner was deemed adequate by the post-conviction court. The petitioner argued that her guilty plea was not entered knowingly and voluntarily, citing her lack of prior experience with the criminal justice system, dissatisfaction with the plea bargain, and her claim of confusion during the plea hearing. However, the court credited trial counsel's testimony, which indicated that he thoroughly explained the plea's nature and consequences, including its finality and the waiver of rights. The court noted that the petitioner actively engaged during the plea hearing, asking questions and affirmatively acknowledging understanding of her situation, including that she was pleading out of range. The transcript confirmed that she was aware of her sentence and that she was not under medication, affirming her decision to plead guilty was voluntary and intelligent. Consequently, the post-conviction court's denial of relief was upheld, confirming the validity of the guilty plea.
