Strickland v. Goguen, No. 19-2104 (1st Cir. 2021)
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The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus under 28 U.S.C. 2254, as amended by the Antiterrorism and Effective Death Penalty Act (AEDPA), holding that the district court did not err in denying the petition.
In his habeas petition, Petitioner alleged that the trial court violated his constitutional rights to a complete defense and to have effective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding (1) the exclusion of certain medical evidence, even if error, was harmless beyond a reasonable doubt; and (2) trial counsel was not constitutionally deficient for not consulting or calling a child abuse expert who could testify to the effects of Munchausen Syndrome by Proxy on fathers like Petitioner.
The court issued a subsequent related opinion or order on July 16, 2021.
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