In Appleby v. Warden, N. Reg'l Jail & Corr. Facility, No. 07-7613, the Fourth Circuit was faced with a criminal defendant's challenge to his sentence of life imprisonment arguing that the recidivist proceeding against him was the consequence of his guilty plea (which he later argued rendered his plea not knowing and involuntary) to drunk-driving related offenses.
In denying defendant's relief, the West Virginia Supreme Court of Appeals (WVSCA) held that because "the imposition of a life sentence is not 'definite, immediate and largely automatic,'" the recidivist proceedings are a collateral consequence of a guilty plea and that the sentencing court did not need to advise a defendant about habitual offender law before accepting a guilty plea to a predicate offense under that law.
In affirming WVSCA's decision, the court found that the recidivist proceedings were not a direct consequence of defendant's guilty plea, and therefore his plea was knowing and voluntary. Thus, the state court's decision was not contrary to or an unreasonable application of established federal law as determined by the Supreme Court.