Penney v. Vaughn

870 F. Supp. 1093, 1994 U.S. Dist. LEXIS 17963, 1994 WL 703482
CourtDistrict Court, M.D. Georgia
DecidedDecember 15, 1994
DocketNo. CA-93-201-1-MAC(DF)
StatusPublished

This text of 870 F. Supp. 1093 (Penney v. Vaughn) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Penney v. Vaughn, 870 F. Supp. 1093, 1994 U.S. Dist. LEXIS 17963, 1994 WL 703482 (M.D. Ga. 1994).

Opinion

FITZPATRICK, District Judge.

On May 17, 1990, authorities transported Ray Michael Penney, II, from jail to the Superior Court of Dooley County, Georgia. Upon his arrival at the courthouse and before arraignment on burglary charges Mr. Penney was approached by Chief Assistant District Attorney Denise Fachini.1 Ms. Fa-chini informed Mr. Penney of his constitutional rights, including the right to counsel, and then inquired as to whether he would be interested in entering a plea of guilty in exchange for the prosecutor’s recommendation of a ten year sentence. Penney agreed to plea in accordance with the offered terms.

[1094]*1094Upon accepting the prosecutor’s terms Mr. Penney was escorted into the courtroom and grouped with four other defendants present on unrelated charges. The judge then conducted an en masse inquiry into the volun-tariness of their collective pleas.2 In accordance with section 33.8(B)(6) of the Uniform Rules of Superior Courts, the judge asked the defendants whether they understood that “at a jury trial you have the right to have a lawyer,” and Penney’s response indicated that he indeed understood. (Transcript of May 17, 1990, proceedings, at 5) (emphasis added). After completion of his examination the judge authorized the entry of Penny’s guilty plea and imposed a ten year sentence.

Penny did not file a direct appeal of his sentence. However, on August 1, 1990, he filed a petition for writ of habeas corpus in the Superior Court of Chatham County, Georgia. The gist of Mr. Penney’s collateral attack was that he had not been provided the assistance of counsel prior to or in connection with the entry of his plea.

Chatham County Superior Court conducted an evidentiary hearing as part of its evaluation of Mr. Penney’s petition. On September 16, 1991, it denied Mr. Penney’s prayer for relief. That court determined that Mr. Penney knowingly and intelligently waived the right to counsel. Penney’s application for a certificate of probable cause was later denied by the Georgia Supreme Court, so he then filed a petition for federal relief pursuant to section 2254 of Title 28, United States Code.

On November 7, 1994, United States Magistrate Judge Claude W. Hicks, Jr., recommended that this court grant Penney’s prayer for relief. The Magistrate Judge noted that the Sixth Amendment right to counsel is a fundamental constitutional right, Gideon v. Wainwright, 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799 (1963), applicable to plea hearings to the same extent as other stages of criminal proceedings. Argersinger v. Hamlin, 407 U.S. 25, 92 S.Ct. 2006, 32 L.Ed.2d 530 (1972).

Primarily the Magistrate Judge’s recommendation focused upon the failure of the trial court to comply with the dictates of Faretta v. California, 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975), which require a “voluntary waiver of the constitutional right to counsel by assertion of the right to self representation.” Stano v. Dugger, 921 F.2d 1125, 1143 (11th Cir.1991) (quoting Faretta, 422 U.S. at 835, 95 S.Ct. at 2541 (citing Johnson v. Zerbst, 304 U.S. 458, 464-65, 58 S.Ct. 1019, 1023, 82 L.Ed. 1461 (1938))). However, respondent Vaughn contends that Faretta’s reach is limited by Stano’s later holding to instances where a defendant wishes to proceed pro se at trial.

Support for Vaughn’s position can be found throughout the Stano opinion:

Under Supreme Court and binding circuit precedent, the Faretta inquiry is reserved for advising a defendant of the disadvantages of proceeding pro se at trial; the plea inquiry is employed for determining whether a defendant’s plea is knowing, intelligent and voluntary sufficient to meet constitutional due process.
There was no need for the trial court to conduct a Faretta inquiry. Based upon Stano’s history of pleading guilty and his actions in this case, it was and is patently apparent that he never envisioned representing himself and proceeding to trial.

Stano, 921 F.2d at 1149.

Stano was distinguished by the Magistrate Judge in a footnote wherein he noted that Penney never received the advice of counsel. The natural inference of the Magistrate Judge’s observation is that Penney was never offered an adequate opportunity to consider [1095]*1095whether a pro se appearance at any proceeding was in his best interests, and therefore one cannot know whether an otherwise-necessary Faretta inquiry was short-circuited.

While the Magistrate Judge accurately identified a factual distinction between Stano and the instant action, one should question whether this dissimilarity is pertinent. Although considerations of efficiency may favor an extension of the prophylactic effect of Faretta so as to negate later collateral attacks like Mr. Penney’s petition, and though a sense of fairness might otherwise incline courts toward ensuring that defendants’ rights are protected, Stano’s broad holding cannot be ignored:

The plea colloquy, provided in Rule 11.., constitutes the constitutional minimum requirements for a knowing and voluntary plea for federal courts, but that rule is not binding on state courts.... A reviewing federal court may set aside a state court guilty plea only for a failure to satisfy due process....

Stano, 921 F.2d at 1141 (citations omitted).

The applicability of a Faretta inquiry is usually not an issue in federal plea hearings because Federal Rule of Criminal Procedure 11(e)(2) requires that a federal court address a defendant personally and in open court to determine whether he or she understands that:

if the defendant is not represented by an attorney, that the defendant has the right to be represented by an attorney at every stage of the proceeding and, if necessary, one will be appointed to represent the defendant....

While recognizing that Rule ll’s requirements do not create a constitutional mandate binding upon states, Gaddy v. Linahan, 780 F.2d 935, 943 n. 8 (11th Cir.1986), the Magistrate Judge nevertheless believed that all courts have a higher responsibility to defendants appearing before them at critical stages of criminal processes than that exhibited in the instant action. The Magistrate Judge further asserted that this higher judicial duty does not end simply with the accused’s waiver of the right to counsel:

To discharge this duty properly in light of the strong presumption against waiver of the constitutional right to counsel, a judge must investigate as long and as thoroughly as the circumstances of the case before him demand.

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Related

Olmstead v. United States
277 U.S. 438 (Supreme Court, 1928)
Johnson v. Zerbst
304 U.S. 458 (Supreme Court, 1938)
Gideon v. Wainwright
372 U.S. 335 (Supreme Court, 1963)
Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
Argersinger v. Hamlin
407 U.S. 25 (Supreme Court, 1972)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
James H. Gaddy v. Leland Q. Linahan, Jr.
780 F.2d 935 (Eleventh Circuit, 1986)
State v. Germany
265 S.E.2d 13 (Supreme Court of Georgia, 1980)
Gideon v. Wainwright
372 U.S. 335 (Supreme Court, 1963)

Cite This Page — Counsel Stack

Bluebook (online)
870 F. Supp. 1093, 1994 U.S. Dist. LEXIS 17963, 1994 WL 703482, Counsel Stack Legal Research, https://law.counselstack.com/opinion/penney-v-vaughn-gamd-1994.