STATE EX REL KNIGHT v. FREDERICK (2021)

Writ application granted. See per curiam.

Writ granted. A voluntary guilty plea waives all nonjurisdictional defects in proceedings against the defendant. State v. McKinney, 406 So.2d 160, 161 (La. 1981); State v. Crosby, 338 So.2d 584, 586 (La. 1976). This includes claims of ineffective assistance of counsel except insofar as the ineffectiveness is alleged to have rendered the guilty plea involuntary. See United States v. Glinsey, 209 F.3d 386, 392 (5th Cir. 2000). Here, defendant's claims of ineffective assistance of counsel were speculative, as the district court determined, and do not relate to the voluntariness of the plea. Accordingly, the court of appeal erred in remanding the case for an evidentiary hearing. The district court did not abuse its discretion when it denied relief summarily based upon its review of the pleadings. See La.C.Cr.P. art. 929(A). The court of appeal's ruling is reversed, and the district court's ruling reinstated.

Hughes, J., dissents. Griffin, J., dissents.