Mannaka Oung v. State of Tennessee

The Petitioner, Mannaka Oung, appeals the Davidson County Criminal Court’s summary dismissal of his petition for post-conviction relief from his 2000 conviction for aggravated assault and resulting three-year suspended sentence. Oung filed a petition for post-conviction relief, alleging that he received ineffective assistance of counsel based on counsel’s failure to advise him of the plea’s possible effects on his immigration status and potential deportation. The post-conviction court concluded that the petition was barred by the statute of limitations and dismissed the petition. On appeal, Oung argues that his claim is based on a constitutional right that did not exist at the time of his plea, such that the statute of limitations does not bar his claim. Upon review, we affirm the judgment of the post-conviction court.