Holder v. United States, No. 10-1304 (8th Cir. 2013)
Annotate this CaseAppellant, convicted of robbing a bank and killing a bank security guard, appealed the district court's Federal Rule of Civil Procedure 59(e) motion to alter or amend the district court's judgment. The court rejected appellant's claims of ineffective assistance of counsel; the district court did not err in denying appellant an evidentiary hearing regarding counsel's alleged failure to adequately investigate his mental health; and the court rejected appellant's Fifth Amendment Indictment Clause claim. Accordingly, the court affirmed the district court's judgment in all respects.
Court Description: Prisoner case - habeas. For the court's opinion affirming Holder's conviction and death sentence, see United States v. Allen, 247 F.3d 741 (8th Cir. 2001), cert. denied, Holder v. United States, 539 U.S. 916 (2003). Claim that trial counsel was ineffective for conceding Holder's participation in the bank robbery rejected as counsel employed a reasonable trial strategy aimed at sparing Holder's life and Holder has not offered any alternative theory under which he would have been found not guilty given the evidence against him and his admissible confession; even if trial counsel was deficient in failing to call an independent ballistics expert, Holder cannot show any prejudice; concerning Holder's claim that counsel was ineffective for failing to object to the instruction on the pecuniary-gain factor,the claim was properly rejected because Holder cannot show that the jury would not have found the factor if the district court had modified the instruction to meet his concerns; claims that counsel was ineffective for failing to adequately investigate Holder's mental health or have an exam by a trauma expert rejected; failure of the indictment to allege an 18 U.S.C. Sec. 3592(c) statutory aggravating factor was harmless since it is clear that the grand jury, if asked, would have charged one of the factors.
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