Woods v. Norman, No. 14-3104 (8th Cir. 2016)
Annotate this CasePetitioner, convicted of second-degree drug trafficking, challenged the denial of his petition for habeas relief under 28 U.S.C. 2254. Petitioner argued that his trial counsel had been constitutionally ineffective because the lawyer failed to interview or present the testimony of petitioner's codefendant. The codefendant had been willing to testify that the drugs belonged to him and that petitioner had no knowledge of their presence in the rental car. On appeal, petitioner contends that the state court contravened federal law when it stated that even if petitioner’s counsel had called codefendant, “the outcome of the proceeding would not have changed.” According to petitioner, the omission from this statement of Strickland v. Washington’s “reasonable probability” language shows that the court applied a more rigorous “sufficiency of the evidence test” when making its prejudice determination. The court agreed with the district court that this alleged imprecision of the state court's opinion fails to demonstrate that its decision was contrary to Strickland’s prejudice standard. The court rejected petitioner's claim that the state court contravened Strickland by basing its prejudice determination on “the subjective views of the trial judge in this court-tried case.” Finally, the state court's application of Strickland's prejudice test was not unreasonable. Accordingly, the court affirmed the judgment.
Court Description: Gruender, Author, with Loken and Kelly, Circuit Judges] Prisoner case - Habeas. The Missouri courts' determination that trial counsel's decision not to call Woods' co-defendant to testify was not ineffective assistance of counsel because Woods could not establish the prejudice prong of Strickland in light of the evidence of his guilt was not contrary to or an unreasonable interpretation of clearly established federal law or based on an unreasonable interpretation of the evidence; alleged imprecision in the language the Missouri Court of Appeals used in evaluating the sufficiency of the evidence did not establish the court acted contrary to Strickland as the court accurately cited the Strickland test in other portions of the opinion; Court of Appeals application of the prejudice prong was not unreasonable based on the record.
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