QUADARIUS DESHUN MARTIN v. STATE OF TENNESSEE - Articles

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Posted by: Karen Belcher on Aug 20, 2025

Head Comment: With dissenting opinion by Matthew Wilson.

Court: TN Court of Criminal Appeals

Attorneys 1: Samuel W. Hinson, Lexington, Tennessee, for the appellant, Quadarius Deshun Martin.

Attorneys 2: Jonathan Skrmetti, Attorney General and Reporter; Benjamin L. Barker, Assistant Attorney General; Jody Pickens, District Attorney General; and Shaun A. Brown, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge(s): SWORD

Pursuant to a negotiated plea agreement, the Appellant, Quadarius Deshun Martin, pled guilty to seven offenses on April 4, 2024, and received an agreed-upon sentence of twelve years’ incarceration. Eighteen days later, the Appellant filed an unsigned, untitled, handwritten pleading in which he stated he wished to withdraw his guilty pleas, arguing that he pled guilty under duress and that trial counsel failed to investigate his case. The trial court1 entered an order construing the filing as a petition for post-conviction relief and appointing counsel. At the subsequent evidentiary hearing, the trial court stated that it would hear both the Appellant’s request to withdraw his guilty pleas and his petition for post-conviction relief. Following the hearing, the trial court denied post-conviction relief but did not rule upon the Appellant’s request to withdraw his guilty pleas. The Appellant appealed, arguing the trial court erred by failing to find he received the ineffective assistance of counsel. We ordered the parties to file supplemental briefs to address whether the trial court erred by construing the Appellant’s filing as a petition for post-conviction relief despite his request to withdraw his guilty plea. Following our review of the record, we reverse the judgment of the trial court and remand for consideration of the Appellant’s motion to withdraw his guilty pleas.