Ramirez v. South Carolina
Annotate this CaseRuben Ramirez was sixteen years old when he was indicted for assault and battery with intent to kill, kidnapping, first-degree criminal sexual conduct with a minor, first-degree burglary, and lewd act upon a child. The issue his case presented for the Supreme Court’s review was whether a severely mentally retarded individual should be afforded post-conviction relief (PCR) where his plea counsel failed to request an independent competency evaluation prior to his guilty plea. The PCR court denied relief, finding plea counsel was not deficient nor was Ramirez prejudiced by counsel's representation. Although the court of appeals disagreed that plea counsel was not deficient, the court affirmed based on its application of the "any evidence" standard to the PCR court's prejudice finding. The Supreme Court affirmed in part and reversed in part, upholding the court of appeals' finding of deficiency but reversing its finding as to lack of prejudice to Ramirez.
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