Donelson v. Steele, No. 20-1094 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of habeas relief to petitioner in an action where petitioner was found guilty of two first-degree murder counts. Although the Missouri Court of Appeals' conclusion that petitioner's counsel performed effectively relied on unreasonable determinations of fact, petitioner failed to show how the error was prejudicial. In this case, the trial court's ruling to deny severance was reasonable and did not amount to an abuse of discretion. Furthermore, even if petitioner could show a substantial probability of severance on appeal, he cannot show an overall reasonable probability of a different outcome in the case. In this case, the evidence against petitioner was convincingly incriminating on both murders and he has not met his burden of showing a reasonable probability of a different outcome in either case even if there was a severance of the cases.
Court Description: [Smith, Author, with Kelly and Erickson, Circuit Judges] Prisoner case - Habeas. The Missouri state court decision determining Donelson was not denied effective assistance of counsel by his trial attorney's decision to withdraw a motion to sever the two murder charges in the prosecution was based on an unreasonable interpretation of the facts; however, Donelson is not entitled to habeas relief because he cannot show prejudice from his attorney's decision to withdraw the motion to sever the two murder charges; the trial court's decision to deny severance was reasonable and did not amount to an abuse of the trial court's discretion; it is therefore, unlikely that the Missouri Court of Appeals would have reversed the trial court's denial of severance; even if Donelson could show a substantial probability of severance on appeal, he cannot show an overall reasonable probability of a different outcome in the case; the evidence against Donelson was convincingly incriminating on both murders, and Donelson has not met his burden of showing a reasonable probability of a different outcome in either case, even if they had been severed. Judge Kelly, dissenting.
The court issued a subsequent related opinion or order on October 26, 2021.
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