State v. Walker
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The Supreme Court of North Carolina was tasked with reviewing the decision of the Court of Appeals related to a defendant's claim of ineffective assistance of counsel. The defendant was convicted of first-degree murder in 1999 and sentenced to life imprisonment without parole. Over two decades later, the defendant filed a motion for appropriate relief (MAR), arguing that his trial counsel did not inform him of his right to testify and prevented him from testifying. He also claimed that his appellate counsel was ineffective because they filed an Anders brief.
The Supreme Court concluded that the Court of Appeals correctly disposed of the defendant's claims. The record demonstrated that the defendant was aware of his right to testify, and there was no evidence to support his claim that his trial counsel prevented him from testifying. Furthermore, the defendant's claim that his appellate counsel was ineffective for failing to challenge limitations on an expert witness’s testimony was without merit because the trial court had appropriately restricted the expert from using legal terminology. Therefore, the defendant's claims of ineffective assistance of both trial and appellate counsel were deemed baseless.
The Supreme Court also held that the standard of review set forth in a previous case, State v. Allen, which involved reviewing MARs in the light most favorable to defendants, was a departure from the court's longstanding standard of review. Thus, the court returned to the previous standard of review, which involves a statutory review pursuant to N.C.G.S. § 15A-1420(c).
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