Smith v. Magnuson

The habeas court properly granted relief to the petitioner based on the invalidity of his guilty pleas, since his mental disorder prevented him from making an intelligent and knowing decision to enter the non-negotiated guilty pleas.

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This is an appeal by the State from the grant of habeas corpus relief to petitioner Andrew Magnuson based on the habeas court’s determination that Magnuson’s guilty pleas were invalid and that he received ineffective assistance of counsel. For the reasons that follow, we find no error in the habeas court’s conclusion that Magnuson’s guilty pleas were invalid and, therefore, we affirm.1

Magnuson was indicted by a Fayette County grand jury on charges of enticing a child for indecent purposes two counts, possession of child pornography, and attempted kidnaping. In 2001, during a group plea, Magnuson entered non-negotiated guilty pleas to all counts of the indictment. During the plea hearing, the judge asked if any defendant had ever been a patient in a mental health facility or under the care of a psychiatrist, and Magnuson incorrectly answered that he had not. Plea counsel informed the judge prior to acceptance of Magnuson’s pleas that Magnuson had in fact been institutionalized and treated for mental health problems but added that he could not say whether psychiatrists had been involved. Counsel then stated that Magnuson had been found competent to stand trial, to which the court responded, “he appears as such.” The court ultimately accepted Magnuson’s pleas without making any further inquiry into his mental health history or his then-current mental state.2 After a sentencing hearing, Magnuson was sentenced to two consecutive 20-year terms of imprisonment on the enticement charges, a consecutive 20-year probated term of imprisonment on the pornography charge, and a consecutive five-year probated term of imprisonment on the attempted kidnaping charge.

Smith v. Magnuson

The habeas court properly granted relief to the petitioner based on the invalidity of his guilty pleas, since his mental disorder prevented him from making an intelligent and knowing decision to enter the non-negotiated guilty pleas.

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