Karen Renee Howell v. State of Tennessee

Summary

The Tennessee Supreme Court affirmed the denial of post-conviction relief to Karen Howell, who pleaded guilty to three counts of felony murder and related offenses arising from the 1997 killings of the Lillelid family. Although defense counsel was deficient in failing to secure and present psychological evidence at Howell's juvenile transfer hearing that she was committable to a mental health facility, the court held the deficiency produced no prejudice because the juvenile court would still have had reasonable grounds to find her non-committable. The court further held that Howell's plea, entered at a group plea hearing under a package agreement sparing her adult co-defendants from the death penalty, was knowing, voluntary, and intelligent, announcing that package plea agreements are not invalid per se and prescribing good-faith and disclosure safeguards. Finally, it upheld the post-conviction court's exclusion of a criminal defense attorney's expert testimony on counsel's effectiveness because it would not substantially assist the trier of fact under Tennessee Rule of Evidence 702.