Smith v. Dickhaut, No. 15-1770 (1st Cir. 2016)Annotate this Case
After a jury trial in the Commonwealth of Massachusetts, Petitioner was convicted of first-degree murder, armed home invasion, and unlawful possession of a firearm. The Supreme Judicial Court (SJC) reversed Petitioner’s conviction for armed home invasion and upheld the remaining conditions. Thereafter, Petitioner sought federal habeas corpus relief in a federal court, asserting three claims. The district court denied the petition. The First Circuit affirmed, holding (1) Defendant’s trial counsel did not provide constitutionally deficient representation; (2) Petitioner’s waiver of his right to testify was not invalid based on erroneous legal advice or Petitioner’s misunderstanding of counsel’s advice; and (3) the SJC did not act contrary to clearly established federal law when it imposed on Petitioner the obligation to show that his waiver was invalid.