Bass v. United States, No. 10-1931 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of conspiring to distribute 50 grams or more of cocaine base. At issue was defendant's subsequent motion for post-conviction relief under 28 U.S.C. 2255 for ineffective assistance of trial counsel. The court held that defendant did not suffer prejudice from the lack of a motion in limine to prevent a witness from testifying because there was overwhelming evidence that defendant participated in a conspiracy to contribute crack cocaine and even had trial counsel successfully moved in limine, there was no reasonable probability that the result of the trial would have been different. The court also held that the prosecutor's contested remarks did not constitute improper vouching and trial counsel could not have been deficient for failing to object during closing argument.
Court Description: Prisoner case - habeas. District court erred in granting Bass habeas relief on his claims of ineffective assistance of counsel; Bass could not suffer any prejudice from the lack of a motion in limine to prevent a witness from testifying as this court found, on direct appeal, that the evidence of Bass's guilt was overwhelming and the exclusion of the witness's testimony would not have affected the outcome of the case; the government did not improperly vouch for its witnesses during closing argument, and counsel could not have been deficient for failing to object to the comments.
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