Garcia v. Mississippi
Annotate this CaseAlberto Garcia confessed to raping and murdering five-year-old JT. He pled guilty to capital murder and waived jury sentencing. After a hearing, the trial judge sentenced Garcia to death. He appealed his sentence, and the Mississippi Supreme Court affirmed. He sought post-conviction relief from his sentence or leave to proceed in the trial court for further post-conviction proceedings. In his motion, Garcia argues his trial counsel provided constitutionally ineffective assistance. While he asserted his attorneys were deficient for three reasons, his primary claim was that counsel failed to pursue and present at the sentencing hearing evidence of fetal alcohol syndrome disorder (FASD) as a mitigating factor. After review, the Supreme Court found Garcia failed to present a substantial showing that his trial attorneys were deficient in investigating potential FASD, let alone that any prejudice resulted. "[T]here is no reasonable probability that FASD evidence would have caused the sentencing judge to find that the mitigators outweighed the aggravators, which included the heinous nature of Garcia’s crime." The Court likewise found Garcia failed to show deficiency and resulting prejudice on his other two ineffective-assistance-of-counsel claims. Therefore, his motion was denied.
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