Archambault v. State
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Zachary Archambault appealed from a district court order denying his application for postconviction relief, arguing that his trial attorney provided ineffective assistance of counsel. Archambault had been found guilty of continuous sexual abuse of a minor child, a class AA felony. Postconviction relief proceedings are civil in nature and governed by the North Dakota Rules of Civil Procedure. In these proceedings, the applicant bears the burden to establish the grounds for relief.
Archambault claimed his trial counsel provided ineffective assistance in six ways. The district court addressed each of his claims and made detailed findings and conclusions regarding each ground. Among his claims, Archambault argued that his trial counsel should have filed a motion to suppress his three-hour video confession because he was suffering from drug and alcohol effects and wanted to self-harm. Additionally, he argued that his trial counsel provided ineffective assistance because he did not interview the minor victim before trial.
The district court found that Archambault did not show his trial counsel’s representation fell below an objective standard of reasonableness. The court made a series of findings that were not induced by an erroneous view of the law and were supported by evidence. These included the court's conclusion that the decision to permit equipment in the jury room is a discretionary decision that will be affirmed absent an abuse of discretion, and that an unsuccessful trial strategy does not make defense counsel’s assistance defective. Based on the Supreme Court's review of the record, it agreed with the district court in denying Archambault’s ineffective assistance of counsel claims, and the order denying his application for postconviction relief was affirmed.
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