LeFebvre v. State
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Danielle LeFebvre was convicted of first-degree child abuse after her seven-week-old son suffered life-threatening injuries. LeFebvre claimed that her son's injuries were accidental, resulting from a fall from her bed. However, medical examinations revealed complex skull fractures, brain contusions, and rib fractures consistent with abuse. LeFebvre was sentenced to twenty years in prison, with eighteen years to serve and the balance suspended, with probation. She appealed her conviction, but it was affirmed.
LeFebvre then filed an application for postconviction relief, arguing that she was deprived of effective assistance of counsel. She claimed her trial counsel failed to consult and present a medical expert at trial and disclosed harmful information to the prosecution. The Superior Court denied her application, finding that her counsel's decision to disclose her medical records was a tactical one and that the absence of expert testimony did not deprive LeFebvre of effective assistance of counsel.
LeFebvre appealed to the Supreme Court of Rhode Island, which affirmed the judgment of the Superior Court. The court found that while the disclosure of LeFebvre's medical records was objectively unreasonable, it did not deprive her of a fair trial given the overwhelming evidence of her guilt. The court also found that the failure to consult and present an expert at trial did not satisfy the criteria for ineffective assistance of counsel.
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