Paulson v. Newton Corr. Facility, No. 13-3406 (8th Cir. 2014)
Annotate this CaseAn Iowa jury convicted Paulson of sexually abusing his five-year-old daughter, M. Paulson’s defense argued that there was no direct, credible evidence. A clinical psychologist testified that the method of questioning M. was coercive. M’s pediatrician and others, including M’s teacher, testified that they observed no physical or emotional signs of sexual abuse. The Iowa Court of Appeals affirmed. Paulson sought post-conviction relief, arguing 18 grounds of ineffective assistance by trial and appellate counsel. Following remand for an evidentiary hearing, the Iowa trial court found that the attorneys’ performance was not deficient and did not result in prejudice, considering failure to object to the testimony of Paulson’s ex-wife that could imply he was sexually violent. The Iowa Court of Appeals agreed, stating that Paulson could not demonstrate that exclusion of that testimony would have resulted in a different outcome. The federal district court denied Paulson’s habeas corpus petition. On remand the court determined that the Iowa decision was contrary to clearly established federal law, considered de novo whether trial counsel was constitutionally ineffective, and determined, in light of the significant evidence against him, that Paulson had failed to show prejudice. The Eighth Circuit affirmed.
Court Description: Prisoner case - habeas. For the court's prior opinion in the matter, see Paulson v. Newton Corr. Facility, 703 F.3d 416 (8th Cir. 2013). On remand the district court did not err in determining that Paulson's attorney's deficient conduct, failure to object to testimony, did not prejudice Paulson as he has failed to show that the outcome of the trial would have been different if the testimony had not been admitted.
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