Background
Coley Djuan Roberts was indicted in 2007 on armed-robbery and capital-murder charges. In 2008, he pleaded guilty to murder and received a life sentence in the custody of the Mississippi Department of Corrections.
In February 2025, Roberts sought post-conviction relief in Lauderdale County Circuit Court. He alleged that his plea was involuntary because he believed he would receive a life sentence with parole eligibility, that counsel was ineffective at the plea and sentencing hearing, and that his sentence was illegal. The circuit court dismissed the motion as untimely and also rejected the claims on their merits.
The Court’s Holding
The Mississippi Court of Appeals affirmed. A defendant who pleaded guilty must generally file a post-conviction motion within three years of the judgment of conviction under Mississippi Code section 99-39-5(2). Roberts filed his motion about seventeen years after his 2008 conviction.
None of Roberts’s claims fit a statutory exception to that limitations period. The court explained that, after Howell, courts may not apply a judicially created fundamental-rights exception to the PCR time bar. Claims of an involuntary guilty plea, ineffective assistance of counsel, and an illegal sentence therefore did not excuse Roberts’s untimely filing.
Key Takeaways
- A PCR challenge following a guilty plea must be filed within three years unless a statutory exception applies.
- Fundamental-rights arguments do not independently overcome Mississippi’s PCR limitations period after Howell.
- Claims attacking plea voluntariness, counsel’s performance, or sentence legality remain time-barred when no statutory exception is shown.
Why It Matters
The decision applies Mississippi’s post-Howell rule strictly: constitutional character alone does not preserve an otherwise untimely PCR claim. Petitioners must identify and establish one of the Legislature’s express exceptions to obtain review outside the three-year period.