Louis Steele v. State of Tennessee

Citation: Not availableDocket: W2005-02480-CCA-R3-PC

Court: Court of Criminal Appeals of Tennessee; November 14, 2006; Tennessee; State Appellate Court

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Louis Steele appeals the dismissal of his post-conviction relief petition by the Shelby County Criminal Court, following guilty pleas to misdemeanor vandalism, harassment, and three counts of driving under the influence (DUI). Steele argues his pleas were not made knowingly and voluntarily due to ineffective assistance of counsel, specifically citing three failures: 1) not informing him that three DUI convictions would classify him as a Motor Vehicle Habitual Offender; 2) neglecting to seek medical treatment while he was incarcerated or to pursue bail; and 3) inadequately conducting a pretrial investigation.

The procedural history reveals that Steele faced five convictions from four indictments, ultimately entering Alford guilty pleas under a plea agreement, which included concurrent sentences totaling eleven months and twenty-nine days for each DUI and other charges, with varying days of confinement. After his pleas, Steele was notified of the State's petition for his classification as a Motor Vehicle Habitual Offender. 

In his pro se post-conviction relief petition filed on February 25, 2005, Steele claimed ineffective assistance of counsel and involuntary pleas. An evidentiary hearing held on August 25, 2005, included testimony from Steele, his brother, and trial counsel. Steele stated that he was never shown evidence or provided with a review of the State’s case, nor was he able to view the destroyed videotapes of his sobriety tests despite requests. He also claimed severe hip pain during his incarceration and that trial counsel failed to act on his need for prescription pain medication prior to plea entry. The appellate court affirmed the post-conviction court’s judgment, upholding the dismissal of Steele's petition.

Trial counsel did not pursue a bond reinstatement for the Appellant to obtain outside medical treatment. The Appellant claimed he was advised by trial counsel to plead guilty to expedite his release from jail for a necessary hip replacement, despite asserting his innocence regarding the DUI charges. He stated that although the trial court informed him of the consequences of pleading guilty, he was not informed that this would classify him as a Motor Vehicle Habitual Offender. Testimony revealed that trial counsel believed the Appellant had a good chance of acquittal on some DUI charges due to insufficient evidence and had communicated this to the Appellant. Counsel also noted the State had lost some evidence, including videotapes of field sobriety tests. The Appellant entered his guilty pleas under the Alford doctrine, but trial counsel admitted he did not inform the Appellant about the habitual offender classification resulting from his guilty pleas. The Appellant had representation by retained counsel during earlier hearings but was represented by an assistant public defender after indictment. The post-conviction court denied relief on September 22, 2005, prompting a timely appeal. The Appellant claims ineffective assistance of counsel, arguing that he was not fully informed of the consequences of his guilty pleas, that counsel failed to seek his medical treatment while confined, and that there was a lack of investigation into the charges. To succeed in his post-conviction claim, the Appellant must demonstrate, by clear and convincing evidence, that his allegations are valid, adhering to T.C.A. 40-30-110(f) (2003). The standard for evaluating the voluntariness of a guilty plea, as established by the U.S. Supreme Court, requires that the plea is a voluntary and intelligent choice among available options.

The reviewing court evaluates the voluntariness and intelligence of a guilty plea by considering the totality of circumstances, which includes the defendant's intelligence, familiarity with criminal proceedings, competency of counsel, and the reasons behind the plea. The effectiveness of counsel only matters in relation to the plea's voluntariness. To challenge ineffective assistance, the appellant must demonstrate that counsel's performance fell below acceptable standards and that this deficiency prejudiced the decision to plead guilty. Specifically, the appellant must show a reasonable probability that, absent counsel’s errors, he would have opted for a trial instead of pleading guilty. The court emphasizes that tactical decisions made by counsel cannot be critiqued unless shown to lack adequate preparation. Furthermore, issues regarding counsel's performance and resulting prejudice are mixed questions of law and fact, with factual findings reviewed de novo but legally conclusions assessed without any presumption of correctness. The appellant argues he was not informed that pleading guilty to three DUI counts would result in automatic classification as a Motor Vehicle Habitual Offender. The post-conviction court rejected this claim, stating that this classification is a civil matter, not a criminal penalty, and emphasized that driving is a privilege, not a right, which does not entail jail time or fines.

The post-conviction court highlighted that the Appellant was informed during the guilty plea hearing that his convictions could enhance future penalties, in accordance with Tennessee law. Relief in post-conviction petitions is only granted when a conviction or sentence infringes upon constitutional rights. A requirement for guilty plea advisements beyond the standards set by Boykin v. Alabama does not equate to a constitutional violation and therefore does not justify post-conviction relief. The court stated that informing a defendant about potential sentence enhancements from prior convictions is not constitutionally mandated, nor is the omission of advising about possible civil penalties. The Appellant's claim of ineffective counsel, based on reliance on R. L. Seaton v. State, was deemed misplaced due to factual differences. The post-conviction court noted that requiring counsel to discuss every potential collateral consequence would lead to impracticality. The Appellant's argument that his guilty pleas were involuntary due to a lack of understanding of their consequences is also unfounded, as a guilty plea represents a formal admission of guilt and consent to conviction without a trial. The Supreme Court's ruling in United States v. Broce clarified that a conscious waiver is not necessary for every defense relinquished by a guilty plea.

Relinquishment of defenses in the context of a guilty plea does not hinge on a defendant’s subjective understanding but rather on the admissions made when entering the plea. The trial court properly adhered to Rule 11 by informing the respondents that pleading guilty constituted an admission of guilt and a waiver of the right to trial. Previous cases establish that ineffective assistance of counsel regarding the constitutional implications of historical facts cannot invalidate a guilty plea, nor does a misunderstanding of penalties related to alternative actions. A defendant is barred from collateral attacks on a guilty plea based on misjudging the admissibility of their confession. 

The Appellant claimed ineffective assistance of counsel for failing to seek medical treatment while incarcerated and for not attempting to reinstate his bond for treatment, asserting that this lack of care motivated his acceptance of the plea agreement. To prove deficient performance, the Appellant needed to demonstrate that a motion for treatment or bond reinstatement would have been granted and that this would have likely altered the trial's outcome. The Appellant did not meet this burden, failing to specify what motions should have been filed or to provide evidence of deprivation of medical assistance. Additionally, no substantial evidence indicated that a motion to reinstate bond would have been viable, as the context showed it would have been challenging. 

The Appellant also alleged that trial counsel was ineffective for not investigating videotapes of his field sobriety tests, which he believed could have provided defenses and influenced his decision to plead guilty. However, the post-conviction court noted that trial counsel was aware that the videotapes either did not exist or had been lost or destroyed, undermining the claim of deficiency in failing to review them. Thus, the allegations of ineffective assistance were not substantiated.

The Appellant was advised by his lawyer that they had a viable chance of winning at trial, indicating his awareness of the weaknesses in the State's case. Despite this, the Appellant opted to proceed to trial, which was scheduled four times. The court noted that the Appellant understood the evidence against him and the risks involved, confirming he was fully aware of his situation. The trial counsel testified to conducting a thorough investigation, although certain key videotapes were unavailable. Counsel believed there were good chances of winning at least two cases but the Appellant did not demonstrate what beneficial evidence might have been uncovered with further investigation. Consequently, the burden of proof rested with the Appellant during the post-conviction hearing. The court concluded that the Appellant's guilty pleas were made with adequate understanding of their implications and affirmed the dismissal of his petition for post-conviction relief, ruling that trial counsel's representation was not deficient.