Caldwell v. Edenfield
Annotate this CaseIn 2009, a jury convicted David Edenfield for the 2007 sexual assault and murder of six-year-old Christopher Barrios, and the jury imposed a death sentence for the murder. Lead trial counsel, joined by other attorneys, represented Edenfield on direct appeal, and, in June of 2013, the Georgia Supreme Court affirmed Edenfield’s convictions and sentences on direct appeal. Edenfield subsequently filed a petition for a writ of habeas corpus, asserting he was ineligible for the death penalty because he is intellectually disabled and that trial counsel provided constitutionally ineffective assistance during his trial in several ways, including by failing to present evidence of Edenfield’s alleged intellectual disability in the sentencing phase as mitigating evidence. He also contended that appellate counsel had provided ineffective assistance. The habeas court denied relief on all claims except for the ineffective assistance of trial counsel claim concerning counsel’s presentation of evidence of Edenfield’s alleged intellectual disability as mitigating evidence in the sentencing phase. Based on that claim, the habeas court vacated Edenfield’s death sentence. The Warden appealed in Case No. S23A0260, and Edenfield has cross-appealed in Case No. S23X0261. In the Warden’s appeal, the Georgia Supreme Court reversed the habeas court’s decision to vacate Edenfield’s death sentence. In Edenfield’s cross-appeal, the Court affirmed in part; the Court conclude as to Edenfield’s claim regarding trial counsel’s alleged deficiency concerning certain allegedly mitigating circumstances that additional findings of fact and conclusions of law were required, and the case was therefore remanded to the habeas court for further proceedings.
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