COA sides with pro se defendant in murder case

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The Indiana Court of Appeals has ruled that a trial court erred when it accepted a man’s guilty plea to murder, because the defendant had at the same time claimed his innocence.

In the case of Stacey R. Huddleston, Jr., v. State of Indiana , No.  20A05-1012-PC-813, Stacey Huddleston appealed the denial of his petition for post-conviction relief, stating that his guilty plea was not entered knowingly, intelligently, and voluntarily, and that he wished to proceed pro se, due to ineffective counsel. He filed the same appeal in March 2010, but the PCR court denied his request. Huddleston now appeals, pro se.

In December 2004, Huddleston’s cousin, Ronald White, called to say that someone had broken into his apartment and stolen Huddleston’s video game system. Huddleston went to White’s apartment with the intent of fighting the suspected burglar – 15-year-old S.G.

Huddleston said he thought his cousin had intended to scare S.G., when White, standing outside, asked Huddleston to go back into the apartment and get his knife. White, Huddleston, and S.G. walked to a store, and White hit S.G. in the face with a soda can. S.G. ran, and White caught up with him, stabbing him once in the back and killing him. Huddleston ran away.

In January 2005, Huddleston was charged with murder. On the morning that the third day of trial was set to begin, Sept. 21, 2005, Huddleston pleaded guilty on advice of counsel. The factual basis for the plea consisted solely of Huddleston being questioned by the deputy prosecutor.

During questioning with the deputy prosecutor, Huddleston said he did not think his cousin was capable of murdering someone and never suspected that would be the outcome when he gave White the knife. Huddleston, responding to a question, agreed that he understood that as an accessory, he was guilty of the crime of murder.

The trial court questioned him further about the guilty plea, and when asked if he had knowingly participated in the murder, Huddleston said, “Yeah. I was there. Yes, sir. I was there, yes, sir.” The court subsequently accepted the guilty plea, sentencing Huddleston to 50 years. On direct appeal, the court affirmed the sentence.

In his most recent appeal, Huddleston contended that by insisting during the guilty plea factual basis hearing that he did not know or intend that S.G. would be killed, the trial court should not have accepted his guilty plea, pursuant to the holdings in Harshman v. State, 232 Ind. 618, 115 N.E.2d 501 (1953), and Ross v. State, 456 N.E.2d 420 (Ind. 1983). In Harshman, the Supreme Court held, “a plea of guilty tendered by one who in the same breath protests his innocence, or declares he actually does not know whether or not he is guilty, is no plea at all. Certainly it is not a sufficient plea upon which to base a judgment of conviction.”

The appeals court wrote that the state has not directly responded to Huddleston’s argument that the trial court’s acceptance of his guilty plea violated the Ross/Harshman rule.

“We cannot conclude that Huddleston’s ultimate ‘yes’ to the question of whether he was guilty of murder was sufficient to override his earlier statements expressly denying the requisite culpability for murder,” the COA wrote.

The court held that the trial court erred in accepting the guilty plea and, consequently, the post-conviction court erred in denying Huddleston’s PCR petition. The appeals court remanded for further proceedings consistent with its opinion.


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  1. Freedom From Religion Foundation: If you really want to be free from religion, don't go to the Christmas Play or the Christmas Pageant or the Christmas Parade. Anything with "Christ" or Saint...fill in the blank...would be off limits to you. Then leave the rest of us ALONE!

  2. So the prosecutor made an error and the defendants get a full remedy. Just one short paragraph to undo the harm of the erroneous prosecution. Wow. Just wow.

  3. Wake up!!!! Lawyers are useless!! it makes no difference in any way to speak about what is important!! Just dont tell your plans to the "SELFRIGHTEOUS ARROGANT JERKS!! WHO THINK THEY ARE BETTER THAN ANOTHER MAN/WOMAN!!!!!!

  4. Looks like you dont understand Democracy, Civilized Society does not cut a thiefs hands off, becouse now he cant steal or write or feed himself or learn !!! You deserve to be over punished, Many men are mistreated hurt in many ways before a breaking point happens! grow up !!!

  5. It was all that kept us from tyranny. So sad that so few among the elite cared enough to guard the sacred trust. Nobody has a more sacred obligation to obey the law than those who make the law. Sophocles No man is above the law and no man is below it; nor do we ask any man's permission when we ask him to obey it. Obedience to the law is demanded as a right; not asked as a favor. Theodore Roosevelt That was the ideal ... here is the Hoosier reality: The King can do no wrong. Legal maxim From the Latin 'Rex non potest peccare'. When the President does it, that means that it is not illegal. Richard Nixon