Ex parte Marcel Davis

Davis · Texas Court of Criminal Appeals · February 17, 2015 · No. WR-09,572-60(R)(A)

Summary

This document is an applicant's objection to a Texas trial court's findings of fact and conclusions of law in a post-conviction habeas corpus proceeding. The applicant argues that trial counsel was ineffective regarding the guilty plea, the alleged omission of a culpable mental state from the indictment, and the admission of extraneous-offense evidence during punishment.

Court
Texas Court of Criminal Appeals
Jurisdiction
Texas
Decision date
February 17, 2015
Docket number
WR-09,572-60(R)(A)
Procedural posture
Applicant Marcel Davis filed an objection to the trial court's findings of fact and conclusions of law in a post-conviction habeas proceeding.
Precedential value
none apparent; supplied document is a party filing rather than a judicial opinion
Parties
Marcel Davis v. State of Texas
Disposition
other

Topics

state post-conviction reliefpost-conviction reliefineffective assistanceplea bargainingcriminal procedure

Practice areas

Texas post-conviction habeas corpuscriminal procedureineffective assistance of counselguilty pleas

Questions Presented

  1. Whether the trial court's findings that Davis's guilty plea was knowing and voluntary were unreasonable because counsel allegedly failed to explain the nature of the charge, the culpable mental state of recklessness, and the consequences of the plea.
  2. Whether trial counsel was ineffective for failing to challenge an indictment that allegedly omitted an essential culpable mental state.
  3. Whether trial counsel was ineffective for eliciting allegedly prejudicial extraneous-offense testimony during the punishment phase without a plausible strategic basis and without requiring notice under Texas law.

Key quotations

Applicant asserts that trial counsel performance was deficient
Applicant asserts that such plea could never be knowingly and voluntary

Factual background

Davis challenged findings that his guilty plea was knowing and voluntary and that trial counsel provided effective assistance. He alleged that counsel failed to advise him about the culpable mental state of recklessness relevant to an injury-to-a-child charge and failed to object to or move to quash an indictment that allegedly omitted that mental state. He also asserted that counsel elicited prejudicial extraneous-offense testimony during punishment by referring to Davis as a drug dealer without a reasonable strategic basis.

Procedural history

The document states that the matter arose from a writ proceeding in the 265th Judicial District Court of Dallas County, Texas. Davis objected to findings supporting the State's position concerning the voluntariness of his guilty plea and the effectiveness of trial counsel. No judicial ruling or disposition by the Texas Court of Criminal Appeals appears in the supplied text.

Court Document

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