State Ex Rel. Troy Knight v. Chris Frederick, Warden

Supreme Court of Louisiana
November 23, 2021
Chief Deputy Clerk of Court
For the Court
The Supreme Court of the State of Louisiana
STATE EX REL. TROY
KNIGHT VS.
CHRIS FREDERICK, WARDEN
No. 2021-KP-01061
_ _
_ _ _ _
I
N RE: State of Louisiana, Department of Transportation and Development -
Applicant Other; Applying For Supervisory Writ, Parish of Jefferson, 24th Judicial
District Court Number(s) 16 -6611, Court of Appeal, Fifth Circuit, Number(s) 21 -
KH-161;
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November 23, 2021
Writ application granted. See per curiam.
Hughes, J., dissents.
Griffin, J., dissents.
WJC
JLW
SJC
JTG
JBM
11/23/2021 "See News Release 046 for any Concurrences and/or Dissents."

S
UPREME COURT OF LOUISIANA
No
. 21-KP-1061
STA
TE EX REL. TROY KNIGHT
v.
CH
RIS FREDERICK, WARDEN
O
N SUPERVISORY WRITS TO THE TWENTY-FOURTH
JUDICIAL DISTRICT COURT, PARISH OF JEFFERSON
PE
R CURIAM:
W
rit granted. A voluntary guilty plea waives all nonjurisdictional defects in
proceedings against the defendant. State v. McKinney , 406 So.2d 160, 161 (La.
1981); State v. Crosby , 338 So.2d 584, 586 (La. 1976). This includes claims of
ineffective assistance of counsel except insofar as the ineffectiveness is alleged to
have rendered the guilty plea involuntary. See United States v. Glinsey , 209 F.3d
386, 392 (5th Cir. 2000). Here, defendant’s claims of ineffective assistance of
counsel were speculative, as the district court determined, and do not relate to the
voluntariness of the plea. Accordingly, the court of appeal erred in remanding the
case for an evidentiary hearing. The district court did not abuse its discretion when
it denied relief summarily based upon its review of the pleadings. See La.C.Cr.P.
art. 929(A). The court of appeal’s ruling is reversed, and the district court’s ruling
reinstated.
11/23/2021