Walden v. State
| Docket Number: | 2014-CT-00165-SCT Linked Case(s): 2014-CP-00165-COA ; 2014-CP-00165-COA ; 2014-CT-00165-SCT |
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| Supreme Court: | Opinion Link Opinion Date: 09-29-2016 Opinion Author: Dickinson, P.J. Holding: Reversed and remanded. |
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| Additional Case Information: |
Topic: Post-conviction relief - Ineffective assistance of counsel - Prejudice - Supporting affidavit Judge(s) Concurring: Waller, C.J., Randolph, P.J., Lamar, Kitchens, King, Coleman and Beam, JJ. Non Participating Judge(s): Maxwell, J. Procedural History: PCR Nature of the Case: PCR |
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| Trial Court: |
Date of Trial Judgment: 02-18-2014 Appealed from: HOLMES COUNTY CIRCUIT COURT Judge: HON. JANNIE M. LEWIS Disposition: Dismissed petition for post-conviction relief Case Number: 2013-0150 |
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| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | Nathaniel Walden a/k/a Nathaniel "Dude" Walden |
NATHANIEL WALDEN (PRO SE) |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: LADONNA C. HOLLAND |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Post-conviction relief - Ineffective assistance of counsel - Prejudice - Supporting affidavit |
| Summary of the Facts: | Nathaniel Walden was convicted of murder and shooting into an occupied dwelling. The Court of Appeals affirmed his convictions. Three years later, Walden filed an application for leave to proceed in the trial court with a petition for post-conviction relief. The petition claimed that Walden had received constitutionally ineffective representation when his attorney had advised him to reject a manslaughter plea without any viable defense to the murder charge. The Supreme Court granted Walden leave to proceed in the trial court with this claim. Walden filed his petition for post-conviction relief in the circuit court which dismissed the petition. Walden appealed, and the Court of Appeals found that the circuit judge had not erred by dismissing Walden’s petition for lack of merit. The Supreme Court granted certiorari. |
| Summary of Opinion Analysis: | The circuit judge found that Walden could not prove prejudice because the evidence at trial supported his conviction for murder. Walden claims his attorney provided ineffective representation by advising Walden to reject a plea for manslaughter. The circuit judge erred by focusing her prejudice analysis on the evidence of guilt at trial. In Lafler v. Cooper, 132 S. Ct. 1376, 1383 (2012), the U.S. Supreme Court held that when a defendant claims his counsel provided ineffective assistance by advising the defendant to reject a plea offer, prejudice is established by showing that “the outcome of the plea process would have been different with competent advice.” Further, the circuit judge found that Walden’s petition failed because it was supported only by his own affidavit. However, the petitioner’s obligation to support his application with affidavits other than his own is not absolute. That obligation may be excused by a showing that the petitioner has good cause for failing to obtain those affidavits. Here, both the circuit judge and the Court of Appeals erred by failing to consider whether Walden sufficiently established good cause for failing to obtain other affidavits. Walden specifically pleaded his counsel’s alleged ineffective assistance, and because he asserted potential good cause for his failure to provide additional affidavits, which the circuit judge failed to consider, the case is reversed and remanded. |
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