Mahaffey v. State

843 S.E.2d 571, 308 Ga. 743
CourtSupreme Court of Georgia
DecidedMay 18, 2020
DocketS20A0118
StatusPublished
Cited by7 cases

This text of 843 S.E.2d 571 (Mahaffey v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mahaffey v. State, 843 S.E.2d 571, 308 Ga. 743 (Ga. 2020).

Opinion

308 Ga. 743 FINAL COPY

S20A0118. MAHAFFEY v. THE STATE.

NAHMIAS, Presiding Justice.

In September 2014, Appellant Charles Mahaffey entered

negotiated guilty pleas to felony murder and aggravated assault in

connection with the stabbing death of Christopher Reynolds.

Appellant now challenges the trial court’s order denying his timely

motion to withdraw his pleas, contending that he did not knowingly,

intelligently, and voluntarily plead guilty. We affirm.

1. The record shows that on February 21, 2014, a Cobb County

grand jury indicted Appellant for malice murder, felony murder,

aggravated assault, and possession of a knife during the commission

of a felony. His trial began on September 29, 2014. The next day,

after jury selection concluded, the prosecutor informed the trial

court that the parties had reached a negotiated plea agreement. The

court then held a plea hearing, and the prosecutor explained that in

exchange for Appellant’s guilty pleas to felony murder and aggravated assault, the State would recommend a sentence of life

with the possibility of parole, nolle pros the remaining charges, and

dismiss an unrelated pending felony theft and drug case against

Appellant. The State also agreed not to oppose Appellant’s parole

when he becomes eligible.

At the plea hearing, the prosecutor proffered that the evidence,

if there were a trial, would show the following. On November 25,

2013, Appellant was hanging out at a house with his girlfriend

Jennifer Brook, her sister Beth, and Beth’s boyfriend Reynolds. The

group got into an argument, and Brook, Beth, and Reynolds decided

to leave. As they got into Reynolds’s truck, Appellant rode his bicycle

down the street, where he yelled at Reynolds and said that he was

going to kill Reynolds. Appellant then rode back toward the house,

got off his bicycle, and used a long hunting knife to stab Reynolds,

who was unarmed, in his abdomen and throat. Reynolds died

moments later from his wounds.

As police officers arrived at the scene, Appellant, who had

minor cuts on his hands, put the bloody knife in a nearby shed where he was staying; testing later showed that the knife had Appellant’s

and Reynolds’s blood on it. Appellant and Brook then agreed that

they would tell the responding officers that they had seen an

unknown man with dreadlocks stab Reynolds. Appellant and Brook

initially told the officers that story, but Beth said that Appellant

stabbed Reynolds, and other witnesses at the scene also identified

Appellant as the assailant. Appellant was arrested, and he and

Brook were separately interviewed. Brook eventually admitted that

Appellant stabbed Reynolds. Appellant then changed his story,

admitting that he stabbed Reynolds but claiming that he acted in

self-defense.

Before the plea hearing, Appellant signed a copy of his

indictment, acknowledging that he was changing his plea from not

guilty to guilty of the felony murder and aggravated assault counts.

Appellant and his plea counsel also signed a 26-question waiver-of-

rights form. One question asked, “Do you understand that you have

the right to remain silent?” Appellant wrote, “Yes.” Appellant also

acknowledged on the form that he understood that if he pled “Not Guilty,” he had the right to a jury trial; “the right to use the power

and process of the Court to compel the production of any evidence,

including the attendance of any witnesses in [his] favor”; and the

right “not [to] have to testify against [him]self.” He also

acknowledged on the form that he understood that he was “giving

up all of those rights” by entering his guilty pleas.

During his colloquy with the trial court, Appellant said that he

was 26 years old, had completed the tenth grade, was not under the

influence of drugs or alcohol, and understood the charges against

him. He acknowledged that he had the right to remain silent, that

the maximum sentence he would receive after pleading guilty would

be life imprisonment, that he could plead guilty or not guilty, that

no one made any promises or threats to influence him to plead

guilty, and that his guilty plea could be used against him in

determining his sentence if he is ever convicted of another crime.

Appellant said that he was satisfied with his plea counsel and that

they had discussed the case.

Appellant confirmed that he understood that if he pled not guilty, he had the right to a jury trial; the right to confront witnesses

against him; the right “to compel the production of any evidence,

including the attendance of any witness in [his] favor”; and the right

to an attorney. The court then asked, “You would not have to testify

against yourself, do you understand that?”; Appellant responded,

“Yes, sir.” The court told Appellant that if he pled not guilty, he

would be presumed innocent and the State would have the burden

of proving his guilt beyond a reasonable doubt. The trial court then

asked if Appellant understood that he “would be giving up all those

rights” by pleading guilty, and Appellant answered, “Yes, sir.”

Appellant’s plea counsel confirmed that Appellant had been

informed of his rights and that counsel believed that Appellant

understood the consequences of his guilty pleas.

The trial court accepted the guilty pleas, finding that they were

“freely and voluntarily made and intelligently entered.” In

accordance with the State’s recommendation, the court sentenced

Appellant to serve life in prison with the possibility of parole for

murder; the aggravated assault count merged. On October 30, 2014, which was in the same term of the trial

court, Appellant, through newly appointed counsel, filed a timely

motion to withdraw his guilty pleas. The record shows no activity for

more than three years, until the motion was amended in January

2018. At an October 1, 2018 hearing on the motion, Appellant

testified that his plea counsel advised him that it would be in his

best interest not to testify at trial and that he pled guilty because he

was “concern[ed]” that he “wouldn’t be able to testify on [his] own

behalf.” He also claimed that he was never informed that after

sentencing, he could not withdraw his guilty pleas as a matter of

right, and that he pled guilty because he believed that he had a right

to withdraw his pleas later. In addition, Appellant testified that he

was “under the impression” that if he went to trial, he could be

sentenced for charges that were not included in the indictment. The

State declined to cross-examine Appellant, and no other witnesses

were called to testify. To rebut Appellant’s claims, the State

submitted his acknowledgment of his guilty pleas on the copy of his

indictment, the signed guilty plea form, the plea hearing transcript, and the final disposition form.

At the conclusion of the hearing, the trial court summarily

ruled that the motion to withdraw the guilty pleas would be denied;

on June 27, 2019, the court entered an order summarily denying the

motion. Appellant then filed this appeal.

2. Before sentence is pronounced, a defendant has an absolute

right to withdraw his guilty plea. See OCGA § 17-7-93 (b). After

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Bluebook (online)
843 S.E.2d 571, 308 Ga. 743, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mahaffey-v-state-ga-2020.