Camacho v. Kelley, No. 17-2332 (8th Cir. 2018)
Annotate this CasePetitioner challenged the district court's denial of his petition for habeas relief after he pleaded guilty to an accomplice to murder charge and was sentenced to life without the possibility of parole. The Eighth Circuit affirmed the district court's judgment and held that petitioner's counsel's initial performance was not deficient under Strickland v. Washington, where counsel's opposition to a state hospital evaluation that could be used against him was an acceptable strategic decision. Furthermore, petitioner failed to prove that counsel was deficient in failing to have a competency evaluation performed prior to the entry of the plea. The court held that, taken as a whole, the evidence was insufficient to establish a reasonable probability that petitioner would have been found incompetent to proceed. Therefore, petitioner could not establish that he was prejudiced by counsel's decisions.
Court Description: Erickson, Author, with Wollman and Shepherd, Circuit Judges] Prisoner case - Habeas. In a state criminal prosecution in which Camacho pleaded guilty to Accomplice to Murder and received a life sentence, the district court did not err in determining that Camacho's lawyers were not ineffective in allowing him to plead guilty without first seeking an evaluation to determine whether he was competent to enter the plea in light of an earlier report that noted that Comacho suffered from PTSD with accompanying frontal lobe disorder; the lawyers were correct in their assessment that the diagnosis was insufficient, standing alone to establish a lack of fitness to proceed to trial or enter a plea; their assessments were buttressed by their observations of Camacho before and during trial; taken as a whole, the evidence was insufficient to establish a reasonable probability that Comacho would have been found incompetent to proceed, and Comacho could not, therefore, establish prejudice
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