Bowen v. Noel
Annotate this CaseRodney Noel was granted habeas relief from his conviction for murdering nine-month-old Terrell Williams (“Terrell”). The habeas court held that Noel’s appellate counsel provided ineffective assistance for two reasons: (1) counsel failed to challenge the trial court’s denial of Noel’s right to impeach his intimate partner and Terrell’s mother, Crystal Williams (“Williams”), using three prior violent acts by her; and (2) counsel failed to assert Noel’s right to use these acts as proof that Williams, not Noel, killed Terrell. The Georgia Supreme Court disagreed with the habeas court that appellate counsel’s performance was constitutionally ineffective. The Supreme Court found Noel’s claim regarding alleged impeachment error failed because it was not preserved at trial and so could not have been successfully raised on appeal. "And Noel has not shown that any deficiency of appellate counsel regarding proof of third-party guilt was prejudicial." Judgment was therefore reversed.
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