The Unappealing Nature of Guilty Plea Agreements: Johnson’s Restrictions on Appeals of Intellectual Disabilities

Abstract

In 2008, Ronald Johnson was charged with the murder of Luke Meiners, a St. Louis attorney. On the advice of his appointed defense counsel, Johnson pleaded guilty to the charge of first-degree murder to avoid the death penalty. Johnson was ineligible, however, for the death penalty because he was intellectually disabled. After his conviction, Johnson appealed for postconviction relief. Johnson received a mental evaluation, which concluded he was competent to stand trial. Thus, the court upheld his guilty plea. In an appeal to the Supreme Court of Missouri, Johnson argued that his conviction should be set aside because he received ineffective assistance of counsel and was coerced into accepting his plea. The Supreme Court of Missouri avoided the merits of Johnson’s appeal because of its technical deficiencies. The court further confused the established standards for competency to stand trial and intellectual disability in a way that will affect the rights of intellectually disabled individuals

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