Sean Eamonn Waite v. Texas

While intoxicated on methamphetamine, petitioner evaded police on a motorcycle with his girlfriend as a passenger. He crashed, and she died at the scene. He pled guilty to felony-murder pursuant to a plea bargain for 28 years in prison. Counsel knew that petitioner suffered traumatic injuries while serving in the military and became addicted to prescription opioids, but he did not independently investigate petitioner’s mental health history. Without an expert, counsel concluded that petitioner had no mitigating explanation for his substance abuse. Petitioner alleged on habeas that his guilty plea was involuntary where counsel failed to investigate, discover, and use compelling mitigating evidence to negotiate a more favorable plea bargain or, alternatively, failed to advise petitioner to plead guilty to a jury to decide punishment. Counsel gave conflicting affidavits and asserted that he made a strategic decision not to investigate petitioner’s mental health because the prosecutor and jurors would view such issues as aggravating. In fact, petitioner suffers from severe depression and anxiety and presents a low risk for future violence. Without conducting an evidentiary hearing to resolve the factual disputes, the habeas court found that counsel was not ineffective. The Texas Court of Criminal Appeals (TCCA) denied relief. The question presented is: Did the TCCA deny petitioner procedural due process by summarily rejecting his substantial constitutional claim without requiring the trial court to resolve the disputed facts?