Darden v. United States, No. 10-15640 (11th Cir. 2013)
Annotate this CaseDefendant was indicted on two counts of obstructing commerce by robbery and two counts of brandishing a firearm in connection with each robbery. At issue on appeal was whether the district court's decision to analyze defendant's ineffective-assistance-of-counsel claim under Strickland v. Washington, rather than presume prejudice under Cronic v. United States, was in error. The court affirmed the district court's judgment, concluding that the district court did not have to presume prejudice where defense counsel, without consulting defendant, conceded that the prosecution had set forth enough evidence to convict defendant of some of the offenses for which he was charged in order to enhance defense counsel's credibility when defending against the other charges.
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