Edgar v. State
Annotate this CaseAfter a jury trial, Defendant was convicted of the felony murder of his son and of the child abuse of two of his other children. Edgar was sentenced to life imprisonment. The Supreme Court affirmed Edgar's convictions and sentences. Defendant subsequently filed a motion for postconviction relief, claiming, among other things, that his counsel was ineffective during closing argument. The district court summarily denied the motion. A panel of the court of appeals reversed without discussing the second prong of the ineffective assistance of counsel test, instead remanding for an evidentiary hearing. The State appealed, claiming that the court of appeals erred when it did not consider the prejudice prong of the Strickland/Chamberlain test. The Supreme Court reversed the court of appeals and affirmed the district judge's denial of Defendant's motion, holding (1) the court of appeals could and should have reviewed the district judge's ruling on the second prong of the Strickland/Chamberlain test, but (2) under the Court's review, the district judge correctly concluded that Defendant failed to establish prejudice.
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