Casey v. US, No. 21-1414 (1st Cir. 2024)
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Lashaun Casey was sentenced to life imprisonment after being found guilty by a jury of carjacking and murdering an undercover police officer. Casey sought a writ of habeas corpus, claiming that his trial attorney failed to seek exclusion of inculpatory statements he made during a period of improper delay in bringing him before a magistrate judge following his arrest and detention. The district court rejected this claim, concluding that while a delay occurred, it was reasonable and necessary for legitimate law enforcement purposes.
The United States Court of Appeals for the First Circuit disagreed with the district court's conclusion that Casey's presentment was justifiably delayed. However, the court agreed with Casey that admission at trial of one of the two contested sets of statements was improper. Despite this, the court concluded that Casey had not demonstrated that his trial counsel's failure to press that error constituted ineffective assistance of counsel because his showing of prejudice fell short of the Sixth Amendment standard. Therefore, the court affirmed the district court's judgment denying the writ of habeas corpus.
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