Steen v. Schmalenberger, No. 11-1136 (8th Cir. 2012)
Annotate this CaseA North Dakota jury convicted Defendant of manufacturing methamphetamine, possessing methamphetamine, and possessing drug paraphernalia, all in violation of state law. After the North Dakota Supreme Court affirmed Defendant's conviction and the denial of his motion for state postconviction relief, Defendant filed a petition for writ of habeas corpus, arguing that the state court erred in requiring him to prove that his counsel's error was prejudicial under Strickland v. Washington. At issue on appeal was whether the wearing of prison clothing was necessarily prejudicial under United States v. Cronic, and therefore, a specific showing of prejudice was not required. The district court denied the petition. The Eighth Circuit Court of Appeals affirmed, holding that based on the record before the state courts, the decision of the Supreme Court was not an unreasonable application of clearly established law.
Court Description: Prisoner case - habeas. For the court's prior opinion in the matter, see Steen v. Schuetzle, 326 F. App'x 972 (8th Cir. 2009). The decision of the North Dakota Supreme Court that Steen failed to show prejudice resulting from trial counsel's failure to object to Steen's appearance at trial in prison attire was not an unreasonable application of clearly established federal law.
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