Dozier v. WatsonAnnotate this Case
The Superior Court of Jenkins County Georgia granted Jeffrey Watson’s petition for a writ of habeas corpus and set aside his convictions for family violence aggravated battery based on its finding that Watson’s plea counsel provided him with ineffective assistance in connection with the entry of his guilty plea. The Warden did not challenge the habeas court’s findings concerning plea counsel’s deficient performance. Rather, the Warden contended only that the habeas court, by “conflating” deficient performance and prejudice, failed to properly analyze whether Watson was prejudiced by counsel’s deficient performance. The Georgia Supreme Court found the deficient performance and prejudice prongs of the Strickland v. Washington, 466 U. S. 668 (1984) test were two separate inquiries, and the habeas court was, required to determine whether Watson had shown “that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” Because the habeas court failed to properly analyze the prejudice prong, its order lacked a factually supported legal conclusion essential to its ruling on Watson’s ineffective assistance of counsel claim and essential to the Supreme Court’s appellate review of that ruling. Therefore, the Court vacated the habeas court’s judgment and remanded this case to the habeas court with instruction to enter a new order consistent containing the requisite findings of fact and conclusions of law.