Byrd v. Workman, No. 09-5146 (10th Cir. 2011)
Annotate this CasePetitioner Kirk Byrd appealed the district court's denial of his habeas petition. Petitioner alleged that he received ineffective assistance of counsel because his trial counsel failed to investigate whether his prior felony convictions would be admissible to enhance his sentence under the state repeat-offender statute. Under Oklahoma law, a criminal defendant facing a sentence enhancement is entitled to a bifurcated trial. In a bifurcated trial, a defendant's prior convictions are not admissible. Faced with the apparent choice of a single-stage trial where he would admit all his prior convictions himself, or a bifurcated trial, Petitioner chose to be up-front about his criminal past, and admitted to each of his previous felony convictions. Upon review by the Tenth Circuit, the Court noted that Petitioner made the strategic decision to admit his prior convictions in a single-stage proceeding. The Court reasoned that it followed the trial court would use those admissions in making its sentencing decision. The Court found no prejudice to Petitioner by his counsel's actions. Accordingly, the Court affirmed Petitioner's conviction and sentence.
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