Heddings v. State
Annotate this CaseScott Heddings was charged with felony incest in State court. While the incest charge was pending, Heddings was charged in federal court with receipt of child pornography, possession of child pornography, and destruction or removal of property to prevent seizure. Heddings pled guilty to federal court to these charges. Heddings then pled guilty to the incest charge in State court. Heddings subsequently filed a petition for postconviction relief, arguing (1) he was subjected to double jeopardy because he was sentenced in State court for conduct that was used to enhance his federal sentence, and (2) his trial counsel was ineffective because counsel did not challenge the State court charge on double jeopardy grounds. The district court denied the petition, concluding that because the federal and State charges were based on separate conduct, Heddings' double jeopardy claim had no legal merit and, therefore, it would have been frivolous for his counsel to raise that claim. The Supreme Court affirmed, holding that the failure of Heddings' trial counsel to move for the dismissal of the State incest charge on double jeopardy grounds did not constitute ineffective assistance since the motion lacked merit and would not have changed the outcome of the proceedings.
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