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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. Thank you, John Smith, for pointing out a needed correction. The article has been revised.

  2. The "National institute for Justice" is an agency for the Dept of Justice. That is not the law firm you are talking about in this article. The "institute for justice" is a public interest law firm. http://ij.org/ thanks for interesting article however

  3. I would like to try to find a lawyer as soon possible I've had my money stolen off of my bank card driver pressed charges and I try to get the information they need it and a Social Security board is just give me a hold up a run around for no reason and now it think it might be too late cuz its been over a year I believe and I can't get the right information they need because they keep giving me the runaroundwhat should I do about that

  4. It is wonderful that Indiana DOC is making some truly admirable and positive changes. People with serious mental illness, intellectual disability or developmental disability will benefit from these changes. It will be much better if people can get some help and resources that promote their health and growth than if they suffer alone. If people experience positive growth or healing of their health issues, they may be less likely to do the things that caused them to come to prison in the first place. This will be of benefit for everyone. I am also so happy that Indiana DOC added correctional personnel and mental health staffing. These are tough issues to work with. There should be adequate staffing in prisons so correctional officers and other staff are able to do the kind of work they really want to do-helping people grow and change-rather than just trying to manage chaos. Correctional officers and other staff deserve this. It would be great to see increased mental health services and services for people with intellectual or developmental disabilities in the community so that fewer people will have to receive help and support in prisons. Community services would like be less expensive, inherently less demeaning and just a whole lot better for everyone.

  5. Can I get this form on line,if not where can I obtain one. I am eligible.

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