Bahtuoh v. Smith, No. 16-2279 (8th Cir. 2017)
Annotate this CaseThe court affirmed the denial of habeas relief under 28 U.S.C. 2254 to petitioner, convicted of first degree felony murder, rejecting his claims that defense counsel provided ineffective assistance by advising him not to testify after counsel had promised the jury that he would. The court concluded that the Minnesota Supreme Court did not unreasonably apply Strickland v. Washington, because defense counsel's change in strategy was based on unexpected developments. The court rejected petitioner's claim that the Minnesota Supreme Court's decision was based on an unreasonable determination of the facts where the record supported the state court's factual findings.
Court Description: Murphy, Author, with Loken and Benton, Circuit Judges] Prisoner case - Habeas. The Minnesota court's did not err in determining counsel did not render ineffective assistance of counsel by advising Bahtuoh not to testify after the close of the government's case where he had told the jury in his opening argument that Bahtuoh would testify on his own behalf; the Minnesota Supreme Court's determination that the change in strategy was reasonable based on unexpected developments during the government's case was not contrary to or an unreasonable interpretation of federal law; nor was the Minnesota Supreme Court's decision based on an unreasonable determination of the facts.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.