Payne v. Brown

Dist. Ct. did not err in denying defendant's habeas petition challenging his guilty plea to four felonies related to rape of 17-year-old boy and 50-year sentence on ground that defendant's trial counsel was ineffective either for failing to reduce plea agreement to writing or for failing to give defendant accurate information about length of potential sentence. While Dist. Ct. could not base instant denial on perception that any error was harmless because defendant would have been convicted had he taken case to trial, denial was nevertheless proper where: (1) trial court advised defendant of potential 50-year sentence at plea colloquy; (2) defendant did not advise trial court during colloquy that his attorney had told him that maximum term that he would receive was only 20 years; and (3) defendant's explanation during colloquy for accepting plea was unrelated to any belief that maximum term was only 20 years.