Williams v. Mississippi
Annotate this CaseIn 1982, Antonio Williams pled guilty to two counts of burglary. The trial judge sentenced him to three years' imprisonment on one count, and five years' imprisonment on the other. Then, in 1987, a jury convicted Williams of murder. The trial judge sentenced him to life without parole as a habitual offender under Mississippi Code Section 99-19-81, based on his two prior burglary convictions. The Mississippi Supreme Court affirmed Williams' murder conviction in 1990. In 2012, Williams filed a motion for post-conviction relief, for the first time challenging his burglary convictions. Williams argued that "during the entry of his guilty pleas," he was "denied his Sixth Amendment right to the effective assistance of counsel." Specifically, Williams argued that his counsel failed to inform him of an alleged speedy-trial violation before advising him to plead guilty to one of the counts. Williams also argued that his trial counsel "used coercion by promising [him] a suspended sentence" in the second count, when a suspended sentence allegedly was not statutorily available. Williams concluded that, because of the alleged Sixth Amendment violation, his guilty pleas could not "be considered to have been given voluntarily and intelligently." The circuit judge summarily denied Williams' motion, stating that "it plainly appears from the face of the motion, exhibits and prior proceedings in this case, that [Williams] is not entitled to post-conviction collateral relief." The circuit judge did not elaborate on his reasons for the denial, but the Supreme Court gathered from the language of his order that the denial was on the merits. It was also clear to the Court that from Williams' motion that he was challenging his burglary convictions and not his murder conviction. Rather than reviewing Williams' appeal on the merits, the Court of Appeals found that the circuit court had lacked jurisdiction to entertain Williams' motion, because he had not obtained permission from the Supreme Court prior to filing there. As such, the Court of Appeals found that it, too, lacked jurisdiction and dismissed Williams' appeal. After review, the Supreme Court agreed with Williams that the circuit court had jurisdiction to hear his motion, but found that the circuit judge did not err when he denied it.
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