The Minnesota Supreme Court ruled Tuesday that a criminal defendant's guilty plea must be withdrawn when his attorney admitted being unprepared for trial and advised pleading guilty as a result. The court held that Tescil Romalis Mason-Kimmons received constitutionally deficient representation that prejudiced his case.
Mason-Kimmons was charged with first-degree murder in connection with the September 2017 shooting death of John Lacy on a Minneapolis street corner in broad daylight. He faced a potential life sentence if convicted at trial. However, his defense attorney acknowledged before trial that he was unprepared to proceed and warned that Mason-Kimmons would not receive a fair trial if forced to go forward with inadequate preparation.
Specifically, Mason-Kimmons's trial counsel stated that he was unprepared, that he would provide ineffective assistance if the case went to trial, and that his client would not get a fair trial if counsel was forced to proceed without adequate preparation. Based on this advice from his attorney, Mason-Kimmons entered a guilty plea to the lesser charge of second-degree intentional murder and received a sentence of 366 months in prison.
Mason-Kimmons filed a direct appeal, which was stayed to allow him to pursue postconviction relief. In his postconviction petition, he sought to withdraw his guilty plea, arguing that his attorney's lack of preparation constituted ineffective assistance of counsel under the Sixth Amendment.
The district court denied Mason-Kimmons's postconviction petition to withdraw his guilty plea. However, the Minnesota Supreme Court reversed that decision in an opinion written by Justice Thissen. Justice Gaïtas took no part in the decision.
The Supreme Court applied the two-prong test established in *Strickland v. Washington* for evaluating ineffective assistance of counsel claims. Under this standard, a defendant must show both that counsel's performance was deficient and that the deficient performance prejudiced the defense.
Regarding the first prong, the court found that Mason-Kimmons's trial counsel's performance was constitutionally deficient. The attorney's own admission that he was unprepared for trial and would provide ineffective assistance demonstrated that his representation fell below the objective standard of reasonableness required under the Sixth Amendment.
For the prejudice prong, the court determined that Mason-Kimmons established a reasonable probability that he would have proceeded to trial rather than pleading guilty if he had received competent counsel. The court explained that counsel's specific advice to plead guilty due to his own lack of preparation created the requisite showing of prejudice.
The Supreme Court emphasized that the case turned on counsel's explicit acknowledgment of his unpreparedness and his advice that Mason-Kimmons should plead guilty as a direct result of that lack of preparation. This distinguishes the case from situations where defendants simply claim their attorneys were generally unprepared or provided inadequate representation.
The ruling establishes important precedent regarding the duties of defense counsel in criminal cases. Attorneys have a constitutional obligation to provide competent representation, which includes adequate preparation for trial. When counsel acknowledges their own unpreparedness and advises clients to plead guilty primarily for that reason, it can constitute both deficient performance and prejudice under the *Strickland* standard.
The decision also highlights the courts' willingness to scrutinize guilty pleas when there are indications that defendants did not receive effective assistance of counsel during the plea process. While guilty pleas are generally given substantial deference, the Supreme Court recognized that constitutional violations during the plea negotiation process can invalidate what might otherwise appear to be voluntary admissions of guilt.
The case was prosecuted by the Hennepin County Attorney's Office under County Attorney Mary F. Moriarty, with Senior Assistant County Attorney Brittany D. Lawonn handling the case. The defense was provided by the State Public Defender's Office, with Chief Appellate Public Defender Cathryn Middlebrook and Assistant State Public Defender Michael McLaughlin representing Mason-Kimmons on appeal.
The Supreme Court's decision reverses the district court's denial of the postconviction petition and remands the case for further proceedings. This means Mason-Kimmons will have the opportunity to withdraw his guilty plea and potentially proceed to trial with different counsel.
The ruling serves as a reminder to defense attorneys of their fundamental obligation to adequately prepare for trial and provide competent representation to their clients. It also demonstrates the courts' commitment to ensuring that constitutional rights are protected even in cases where defendants have entered guilty pleas.