Robert Earl Manuel a/k/a Robert Maunel v. State of Mississippi;

CourtCourt of Appeals of Mississippi
DecidedOctober 20, 2020
DocketNO. 2019-CA-01145-COA
StatusPublished

This text of Robert Earl Manuel a/k/a Robert Maunel v. State of Mississippi; (Robert Earl Manuel a/k/a Robert Maunel 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
Robert Earl Manuel a/k/a Robert Maunel v. State of Mississippi;, (Mich. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2019-CA-01145-COA

ROBERT EARL MANUEL A/K/A ROBERT APPELLANT MAUNEL

v.

STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 06/11/2019 TRIAL JUDGE: HON. TOMIE T. GREEN COURT FROM WHICH APPEALED: HINDS COUNTY CIRCUIT COURT, FIRST JUDICIAL DISTRICT ATTORNEYS FOR APPELLANT: MERRIDA COXWELL CHARLES RICHARD MULLINS ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: JEFFREY A. KLINGFUSS NATURE OF THE CASE: CIVIL - POST-CONVICTION RELIEF DISPOSITION: REVERSED AND REMANDED - 10/20/2020 MOTION FOR REHEARING FILED: MANDATE ISSUED:

EN BANC.

WILSON, P.J., FOR THE COURT:

¶1. Robert Earl Manuel pled guilty to accessory before the fact to second-degree murder

and accessory before the fact to aggravated assault. The circuit court sentenced Manuel to

serve concurrent terms of twenty-five years and twenty years in the custody of the

Mississippi Department of Corrections (MDOC). Manuel subsequently filed a motion for

post-conviction relief (PCR) in which he alleged that his plea was involuntary because his

attorney erroneously advised him that the charges to which he pled guilty were not

considered violent crimes, that he would be eligible for “good time credit,” and that he would be out of prison in “a few short years.” The circuit court summarily dismissed Manuel’s PCR

motion without an evidentiary hearing. We conclude that Manuel presented sufficient

evidence to require an evidentiary hearing. Therefore, we reverse and remand for further

proceedings consistent with this opinion.

FACTS AND PROCEDURAL HISTORY

¶2. Manuel was indicted for first-degree murder, aggravated assault, and shooting into a

vehicle. Pursuant to a plea bargain, he agreed to plead guilty as an accessory before the fact

to second-degree murder and accessory before the fact to aggravated assault. In exchange,

the State agreed to nolle prosequi the shooting-into-a-vehicle charge and unrelated drug

charges under another indictment. The State also agreed to recommend concurrent sentences

of twenty-five years and twenty years. At the plea hearing, the State explained the factual

basis for the charges.1 Manuel told the judge that he did not agree with the factual basis

presented by the State but would enter a “best interest” plea. See North Carolina v. Alford,

400 U.S. 25, 37-38 (1970) (holding that a court may accept a guilty plea even if the defendant

is unwilling to expressly admit guilt).

¶3. The circuit judge then questioned Manuel regarding his understanding of a “best

interest” plea. The judge explained that Manuel would plead guilty as an accessory before

the fact to second-degree murder and aggravated assault and that there was “no murder

charge against [him].” The judge then asked Manuel to explain his understanding of a best

1 Manuel and his cousin argued with Justin Shannon. Hours later, Manuel and his cousin pulled up alongside Shannon’s car and opened fire on the car. They killed Shannon and gravely injured Kendrea Mitchell, a passenger in Shannon’s car. Mitchell identified Manuel and his cousin as the shooters.

2 interest plea. Manuel stated that it was “[t]he best thing to get [him] back to home with [his]

son.” The judge asked Manuel if he was pleading guilty because he understood and agreed

that there was enough evidence to convict him on the charges in the indictment and because

he believed that it was in his “best interest” to “plead[] guilty to a lesser charge of accessory

before the fact.” Manuel answered in the affirmative.

¶4. The judge then discussed the applicable sentencing ranges and the rights that Manuel

would waive by pleading guilty. The judge asked Manuel if he was satisfied with his

attorney and if his attorney had advised him regarding his rights, the charges against him, and

possible defenses. Manuel answered yes to all of the judge’s questions and confirmed that

he wanted to plead guilty because it was his “best option under the circumstances.” The

judge then accepted the plea and the State’s sentencing recommendation. After imposing

Manuel’s sentence, the judge stated, “This [sentence] does allow you though to have some

participation in the activities because it’s not as a habitual, which could have put you in a

position where you couldn’t learn anything, you couldn’t participate, you couldn’t earn any

time. You can do that.”

¶5. Eleven months later, Manuel’s attorney filed a “Motion to Modify Sentencing Order.”

The motion stated that MDOC had “interpreted” Manuel’s conviction for accessory to

second-degree murder “as a violent offense.” The motion asserted that MDOC’s

interpretation was erroneous because Manuel pled guilty to “simple Accessory before the

fact, which is non-violent.” The motion asked the court to modify the sentencing order to

clarify that Manuel pled guilty as an “Accessory before the fact.” The court denied the

3 motion. The court’s order stated that the statutory definition of a “violent crime” controlled

and was consistent with Manuel’s plea.2

¶6. Manuel then retained new counsel and filed a PCR motion, alleging that “his plea of

guilty . . . was not knowingly and intelligently made and was the product of ineffective

assistance of counsel by [his prior] attorney.” The motion alleged that Manuel’s original

attorney, Dennis C. Sweet IV, told Manuel that the charges to which he pled guilty were not

violent crimes; that he would be eligible for “good time credit”3; and that, as a result, he

would be out of prison in “a few short years.” Manuel’s PCR motion relied on his own

affidavit and Sweet’s unsuccessful “Motion to Modify Sentencing Order.”

¶7. The circuit court summarily dismissed Manuel’s PCR motion. The court stated that

Manuel’s PCR motion “raise[d] the same argument” as his prior motion to modify his

sentence and failed to state a “basis for post-conviction relief.” Manuel subsequently filed

a notice of appeal.4

ANALYSIS

2 The statute makes clear that murder and aggravated assault are both violent offenses. Miss. Code Ann. § 97-3-2(b)-(c) (Rev. 2014). The law also makes clear that an accessory before the fact “shall be deemed and considered a principal, and shall be . . . punished as such.” Miss. Code Ann. § 97-1-3 (Rev. 2014). 3 We understand this phrase to be a reference to earned time, Miss. Code Ann. §§ 47- 5-138 & -139 (Rev. 2015); trusty earned time, id. § 47-5-138.1 (Rev. 2015); and/or meritorious earned time, id. § 47-5-142 (Rev. 2015). 4 Manuel attempted to submit additional affidavits after the circuit court denied his PCR motion. On appeal, the State argues that we should not consider these additional affidavits. We conclude that Manuel was entitled to an evidentiary hearing even without the affidavits. Therefore, we need not address the issue.

4 ¶8. Manuel’s only argument on appeal is that the circuit court erred by dismissing his

PCR motion without an evidentiary hearing. Under the Uniform Post-Conviction Collateral

Relief Act, a court may summarily dismiss a PCR motion without an evidentiary hearing “[i]f

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Related

North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
Ware v. State
379 So. 2d 904 (Mississippi Supreme Court, 1980)
State v. Santiago
773 So. 2d 921 (Mississippi Supreme Court, 2000)
Thomas v. State
881 So. 2d 912 (Court of Appeals of Mississippi, 2004)
Gable v. State
748 So. 2d 703 (Mississippi Supreme Court, 1999)
Edmond Quintezes Mosley v. State of Mississippi
150 So. 3d 127 (Court of Appeals of Mississippi, 2014)
Sylvester v. State
113 So. 3d 618 (Court of Appeals of Mississippi, 2013)

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Robert Earl Manuel a/k/a Robert Maunel v. State of Mississippi;, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-earl-manuel-aka-robert-maunel-v-state-of-mississippi-missctapp-2020.