Abdullah v. State
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In 2004, Azad Abdullah was convicted and sentenced to death for the first-degree murder of his wife. He also received consecutive prison sentences for first-degree arson, three counts of attempted first-degree murder, and felony injury to a child. In this appeal, Abdullah challenged the summary dismissal of his second successive petition for post-conviction relief. He claimed that the state suppressed material impeachment information related to its lead investigator, and that his trial counsel was constitutionally ineffective in failing to discover and use this information against the investigator at trial.
The Supreme Court of the State of Idaho affirmed the district court's summary dismissal of both claims in Abdullah’s petition. The court determined that the claims were time-barred under Idaho Code section 19-2719(5) because Abdullah’s prior counsel reasonably could or should have known about the claims Abdullah now raises. The court also found that even if the factual allegations in the petition were true, the information could have been used to impeach the lead investigator at trial or sentencing, but it was neither material to the guilt or penalty phase, nor was trial counsel’s alleged failure to investigate the information prejudicial. Therefore, Abdullah’s challenge to the district court’s discovery ruling was moot.
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