Joiner v. State

Summary

The Supreme Court of Mississippi held that a knowing and voluntary guilty plea waived Albert Joiner’s objection that the indictment failed to charge him as a habitual offender. The court affirmed the denial of post-conviction relief and the Court of Appeals’ judgment, while a dissent argued that the guilty plea did not waive the indictment and due-process requirements under Uniform Rule of Circuit and County Court Practice 7.09.

Holdings

1. A defendant's right to be indicted as a habitual offender may be waived by a knowing and voluntary guilty plea. Joiner's plea knowingly and voluntarily waived his right to challenge the indictment's failure to include habitual-offender status.

Questions Presented

1. Whether a knowing and voluntary guilty plea waives a defendant's right to challenge sentencing as a habitual offender when the indictment did not charge habitual-offender status.

Disposition

affirmed