Elam v. Denny, No. 10-3465 (8th Cir. 2011)
Annotate this CaseDefendant was convicted in Missouri state court and sentenced to life in prison for the first degree murder of his grandfather, armed criminal action, and second-degree arson. Defendant appealed the district court's denial of his petition for federal writ of habeas corpus, arguing that the state courts erred in finding him competent to stand trial and in concluding that trial counsel's failure to call the mental health professionals was not constitutionally defective performance. The court held that, based on the court's review of of the record, nothing suggested that defendant's behavior or demeanor at trial casted doubt on his competency or that counsel again raised this issue. The court also held that trial counsel's performance was not deficient by failing to present cumulative, no-more-favorable expert testimony. Because the court upheld the state court's resolution of the deficient performance issue, the court need not address the district court's alternative prejudice ruling.
Court Description: Prisoner case - habeas. Both the trial court and the Missouri Court of Appeals correctly applied the Supreme Court's clearly established competency standard; failure to present cumulative evidence did not constitute ineffective assistance of counsel, and trial counsel reasonably decided that the doctor he produced was best positioned to testify as to Elam's current medical condition.
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