Background
Mariya Ajena Jones appealed the February 27, 2024, order of the Circuit Court of Cabell County denying her amended petition for a writ of habeas corpus. She appeared through counsel Bradley D. Dunkle. The respondent appeared through Attorney General John B. McCuskey and Deputy Attorney General Andrea Nease; the decision notes that the Attorney General’s name was substituted because a new Attorney General took office while the appeal was pending.
The underlying prosecution arose after Jones and her husband, Aaron Miles, found her three-year-old son unresponsive in the bathroom of their home after leaving the boy alone. Paramedics transported the child to a hospital but determined that he was dead by the time they arrived. Jones and Miles were indicted on numerous charges connected to the child’s death and the neglect of other children in the home.
At the beginning of a joint trial, Jones pleaded guilty to three counts of child abuse causing serious bodily injury as an aider and abettor. The circuit court accepted the pleas after finding a factual basis for them. Jones later chose not to testify, while Miles testified in his defense. A jury found Jones and Miles guilty of various charges connected to the child’s death, including murder of a child by a parent, guardian, or custodian. Jones received a life sentence without the possibility of parole. In State v. Jones, No. 18-0162, 2020 WL 1487802 (W. Va. Mar. 23, 2020) (memorandum decision), the Court held that the circuit court did not err in denying Jones’s motion to sever and affirmed her convictions.
The Court’s Holding
After Jones filed for habeas relief, the circuit court appointed counsel, who submitted an amended petition. The court then conducted an evidentiary hearing at which both Jones and her trial counsel testified. Its February 27, 2024, order found no reason, based on the hearing testimony, to question Jones’s mental competency at trial. It also relied on the Court’s earlier decision rejecting her severance argument. The court further concluded from the plea colloquy that Jones’s three guilty pleas were “voluntarily, knowingly, and intelligently entered.”
The circuit court rejected Jones’s assertion that trial counsel prevented her from testifying, finding that the claim was not credible and was unsupported by the evidence. It also rejected her ineffective-assistance claim. Based on trial counsel’s testimony, the court found that counsel’s performance was not deficient and, alternatively, that any alleged deficiencies would not rise to the level necessary to warrant relief. The circuit court additionally rejected claims alleging sentencing errors and ex parte communications between the trial judge and prosecutor; Jones did not challenge those findings on appeal.
On appeal, Jones raised five issues: the circuit court’s alleged failure to evaluate her competency to stand trial, the joint trial, her guilty pleas allegedly entered on counsel’s erroneous advice, counsel’s alleged prevention of her testimony, and counsel’s alleged cumulative errors. Applying Mathena v. Haines, 219 W. Va. 417, 633 S.E.2d 771 (2006), the Court reviewed the order and ultimate disposition for abuse of discretion, underlying factual findings for clear error, and questions of law de novo. It concluded that the circuit court thoroughly addressed each claim and that Jones had not carried her burden of demonstrating error. Citing Dement v. Pszczolkowski, 245 W. Va. 564, 859 S.E.2d 732 (2021), the Court emphasized the appellant’s burden and the presumptions favoring the proceedings and judgment below. Finding no substantial question of law and no prejudicial error, the Court issued a memorandum decision without oral argument under West Virginia Rule of Appellate Procedure 21(c) and affirmed the denial of habeas relief.
Key Takeaways
- The Court affirmed the denial of Jones’s amended habeas petition and found no abuse of discretion in that disposition.
- The circuit court’s credibility determination defeated Jones’s claim that trial counsel prevented her from testifying; the appellate Court found no error in the rulings below.
- The plea colloquy supported the circuit court’s conclusion that Jones’s three guilty pleas were voluntary, knowing, and intelligent.
- The Court did not revisit severance as a new issue; the circuit court noted that Jones’s direct appeal had already rejected her claim that denial of severance was erroneous.
Why It Matters
The decision illustrates the layered standards governing habeas appeals in West Virginia: de novo review of legal questions, clear-error review of factual findings, and abuse-of-discretion review of the ultimate disposition. It also underscores that the appellant bears the burden of establishing error, with presumptions favoring the correctness of the proceedings and judgment below.
The memorandum decision leaves the circuit court’s findings and the denial of relief intact. Its treatment of the unchallenged sentencing-error and ex parte-communication findings is limited to noting that Jones did not contest them on appeal; the Court announced no broader ruling on those claims.