Winfield v. Dorethy, No. 19-1441 (7th Cir. 2020)
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Winfield confessed to shooting Garrett. Winfield was convicted of attempted murder. Winfield was also accused of killing Stovall in the same shooting but was acquitted on that charge because no credible witness had placed Winfield at the scene of the crime and his confession did not mention Stovall. The judge rejected Winfield’s argument that his confession was coerced and his “half-hearted” alibi defense. On appeal, Winfield raised one unsuccessful sentencing argument. Illinois state courts, on post-conviction review, concluded that trial counsel’s presentation of Winfield’s alibi was not so deficient that it violated the Constitution; they did not meaningfully address the performance of appellate counsel. On federal habeas review, the district court concluded that the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2254(d), did not apply because the ineffective assistance claim had not been adjudicated on the merits in state court. It considered the claim without any deference to the state courts and found appellate counsel had rendered ineffective assistance by omitting an argument that Winfield’s confession was uncorroborated.
The Seventh Circuit held that Winfield is not entitled to relief. Winfield cannot overcome the deference applied to the state court’s finding that trial counsel performed reasonably because Winfield never told counsel that he was at home at the time of the shooting. The Constitution did not obligate Winfield’s appellate counsel to discover and present a complex and novel corpus delicti argument that may not have succeeded.
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