United States v. Steele, No. 12-30005 (9th Cir. 2013)
Annotate this CaseDefendant was convicted of murder-for-hire and victim tampering. On appeal, defendant argued that the district court erred by denying his pre-judgment motion for new trial without reaching the merits of his claim of ineffective assistance of trial counsel. The court concluded that the district court did not err in this case by deferring consideration of defendant's ineffective-assistance-of-counsel claim to collateral review, when a complete record would be available. Accordingly, the court affirmed the district court's order denying the motion for a new trial.
Court Description: Criminal Law. Affirming the district court’s order denying a criminal defendant’s motion for new trial, the panel held that although consideration of a pre-judgment ineffective-assistance-of- counsel claim is appropriate in some cases, the district court did not abuse its discretion here by deferring consideration of the defendant’s ineffective assistance claim to collateral review, when a complete record would be available.
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