Carlos Lawson a/k/a Carlos Cortez Lawson v. State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedDecember 17, 2024
Docket2023-CP-01008-COA
StatusPublished

This text of Carlos Lawson a/k/a Carlos Cortez Lawson v. State of Mississippi (Carlos Lawson a/k/a Carlos Cortez Lawson v. State of Mississippi) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carlos Lawson a/k/a Carlos Cortez Lawson v. State of Mississippi, (Mich. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2023-CP-01008-COA

CARLOS LAWSON A/K/A CARLOS CORTEZ APPELLANT LAWSON

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 07/27/2023 TRIAL JUDGE: HON. STANLEY ALEX SOREY COURT FROM WHICH APPEALED: COVINGTON COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: CARLOS LAWSON (PRO SE) ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: ALLISON ELIZABETH HORNE NATURE OF THE CASE: CIVIL - POST-CONVICTION RELIEF DISPOSITION: AFFIRMED - 12/17/2024 MOTION FOR REHEARING FILED:

BEFORE WILSON, P.J., McCARTY AND SMITH, JJ.

SMITH, J., FOR THE COURT:

¶1. Carlos Lawson appeals from the Covington County Circuit Court’s order denying his

motion for post-conviction collateral relief (PCR). On appeal, Lawson argues that (1) his

trial attorney’s alleged ineffective assistance rendered his guilty plea to fourth-offense

driving under the influence (DUI) involuntary, and (2) his indictment was defective. Finding

no error, we affirm the circuit court’s order denying Lawson’s PCR motion.

FACTS

¶2. A Covington County grand jury indicted Lawson as a violent habitual offender

(thereby exposing Lawson to a potential life sentence) for a fourth DUI offense in Cause

Number 2021-004-K2. Lawson pled guilty to the charge. He also pled guilty to fourth- offense DUI in two additional cause numbers (Simpson County Cause Number 2021-015-K2

and Covington County Cause Number 2021-022-K2). For these three convictions, the circuit

court sentenced Lawson as a nonviolent habitual offender to consecutive terms totaling

fifteen years to serve in the custody of the Mississippi Department of Corrections.1

¶3. Lawson filed a timely PCR motion relating to his conviction and sentence in

Covington County Cause Number 2021-004-K2. Lawson argued that his trial attorney had

provided ineffective assistance. Specifically, Lawson stated that his trial attorney had

misinformed him that he would receive concurrent (rather than consecutive) sentences for

his fourth-offense DUI charges, failed to challenge the sufficiency of the State’s evidence

of his prior DUI convictions, and failed to assert that the indictment was defective due to

incorrect information included about his prior DUI convictions. Lawson further argued that

his trial attorney’s ineffectiveness caused him to enter an involuntary guilty plea. As exhibits

to his PCR motion, Lawson attached an affidavit from himself and his then-fiancée. Both

affidavits asserted Lawson’s trial attorney had informed Lawson that the State’s

recommendation would be to drop his habitual-offender status and allow him to serve

concurrent sentences.

¶4. Lawson’s testimony at his PCR hearing differed from the arguments raised in his PCR

1 For Lawson’s conviction in Covington County Cause Number 2021-004-K2, the circuit court sentenced Lawson as a nonviolent habitual offender to ten years, with three years to serve and seven years suspended, and four years of “unsupervised probation.” For Lawson’s conviction in Simpson County Cause Number 2021-015-K2, the circuit court sentenced Lawson to a consecutive term of ten years, with two years to serve and eight years suspended, and five years of “supervised probation.” For Covington County Cause Number 2021-022-K2, the circuit court sentenced Lawson as a nonviolent habitual offender to serve a consecutive term of ten years in custody.

2 motion and the attached affidavits. Lawson testified that his trial attorney had “told [him]

to do six months alcohol and drugs, complete the program, the habitual will be dropped, and

[Lawson would] be on some type of probation when [he got] released.” On cross-

examination, Lawson admitted that when he entered his guilty plea on July 22, 2021, he had

been charged with three separate counts of fourth-offense DUI as a violent habitual offender

under Mississippi Code Annotated section 99-19-83 (Rev. 2020). When asked, Lawson

acknowledged that he knew the minimum sentence for a fourth-offense DUI charge was “2

to 10 [years].” Despite the signed plea petition attached as an exhibit to his PCR motion,

Lawson denied signing any document specifying that he would serve actual prison time

rather than only six months enrolled in an alcohol-and-drug program. Following the

evidentiary hearing, the circuit court entered an order denying Lawson’s PCR motion.

Aggrieved, Lawson appeals.

STANDARD OF REVIEW

¶5. “When reviewing a circuit court’s denial or dismissal of a PCR motion, we . . . disturb

the circuit court’s decision if the circuit court abused its discretion [or] the decision is clearly

erroneous; however, we review the circuit court’s legal conclusions under a de novo standard

of review.” Johnson v. State, 385 So. 3d 467, 469 (¶6) (Miss. Ct. App. 2023) (quoting Green

v. State, 242 So. 3d 176, 178 (¶5) (Miss. Ct. App. 2017)).

DISCUSSION

I. Ineffective Assistance and Involuntary Guilty Plea

¶6. Lawson contends that his trial attorney’s allegedly incorrect advice about his sentence

3 constituted ineffective assistance of counsel and rendered his guilty plea involuntary.

Because these claims are intertwined, we address them together.

¶7. To succeed on his ineffective-assistance claim, Lawson must establish that (1) his trial

attorney’s “performance was deficient,” and (2) “the deficient performance prejudiced [his]

defense.” Hughes v. State, 321 So. 3d 1244, 1247 (¶7) (Miss. Ct. App. 2021). “[A]

voluntary guilty plea waives claims of ineffective assistance of counsel, except insofar as the

alleged ineffectiveness relates to the voluntariness of the giving of the guilty plea.” Malone

v. State, 379 So. 3d 388, 397 (¶23) (Miss. Ct. App. 2024) (quoting Thomas v. State, 159 So.

3d 1212, 1215 (¶10) (Miss. Ct. App. 2015)). “A plea is considered voluntary when the

defendant knows what the elements are of the charge against him, including an understanding

of the charge and its relation to him, what effect the plea will have, and what the possible

sentence might be because of his plea.” Wade v. State, 379 So. 3d 983, 989-90 (¶16) (Miss.

Ct. App. 2024) (quoting Williams v. State, 220 So. 3d 996, 1000 (¶10) (Miss. Ct. App.

2017)).

¶8. As the defendant, Lawson “bears ‘the burden of proving by a preponderance of the

evidence that his guilty pleas were involuntary.’” Id. at 990 (¶16) (quoting Williams, 220 So.

3d at 1000 (¶10)). In addition, because Lawson pled guilty, he “can only prevail on his claim

[of ineffective assistance of counsel] by demonstrating that there is a reasonable probability

that, but for counsel’s unprofessional errors, the result of the proceeding would have been

different.” Tran v. State, 373 So. 3d 597, 600 (¶6) (Miss. Ct. App. 2023) (citation and

internal quotation marks omitted). Lawson also “must convince the court that a decision to

4 reject the plea bargain would have been rational under the circumstances.” Malone, 379 So.

3d at 397 (¶23) (quoting Padilla v. Kentucky, 559 U.S. 356, 372 (2010)).

¶9. In considering Lawson’s claims, “[t]his Court is entitled to place great weight on the

sworn testimony of a defendant . . . , and a defendant faces a rather high hurdle in recanting

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Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
Baldwin v. State
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Kevin Thomas v. State of Mississippi
159 So. 3d 1212 (Court of Appeals of Mississippi, 2015)
Joshua Williams v. State of Mississippi
220 So. 3d 996 (Court of Appeals of Mississippi, 2017)
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Cite This Page — Counsel Stack

Bluebook (online)
Carlos Lawson a/k/a Carlos Cortez Lawson v. State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carlos-lawson-aka-carlos-cortez-lawson-v-state-of-mississippi-missctapp-2024.