Dansberry v. Pfister

Dist. Ct. did not err in denying defendant’s habeas petition, alleging that his guilty plea was involuntary, and that state trial court violated his constitutional rights during his guilty plea hearing by erroneously admonishing him that his mandatory minimum sentence on murder and attempted armed robbery charges was 20 years, instead of 26 years. Record showed that trial court correctly informed defendant that he could face either life imprisonment or death sentence, and Ct. of Appeals found that although trial court erred in informing defendant about wrong mandatory minimum sentence, said error was subject to harmless error analysis. Moreover, said error had no substantial and injurious effect on defendant’s guilty plea hearing, where: (1) record contained no evidence that defendant would have changed his “blind” guilty plea had he known of actual mandatory minimum sentence; (2) at time of guilty plea hearing, defendant was more concerned about avoiding potential of death sentence; and (3) although defendant ultimately received 80-year sentence, he expected to receive about 40-year term of incarceration by pleading guilty.