Williams v. RudolphAnnotate this Case
Following the partial grant of Rajkumar Rudolph's petition for a writ of habeas corpus, Warden Stanley Williams appealed arguing that the trial court erred by finding that Rudolph had received ineffective assistance of appellate counsel. Specifically, the habeas court found that Rudolph was harmed by appellate counsel's failure to challenge the trial court's decision to charge Rudolph's jury with the crime of statutory rape as a lesser included offense of rape. The Supreme Court reversed the habeas court and reinstated the trial court's conviction for statutory rape: at the time of Rudolph's appeal, there was caselaw indicating that statutory rape could be a lesser included offense of forcible rape as a matter of fact. Therefore, examining appellate counsel's perspective at the time of Rudolph's appeal, it was not unreasonable for her not to challenge the trial court's decision to charge Rudolph's jury on the crime of statutory rape.