State v. Bonds
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The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions on the grounds that his counsel had been ineffective, holding that errors on the part of trial counsel did not prejudice Defendant.
Defendant was convicted of murder and several related charges. The court of appeals vacated the convictions, determining that trial counsel was ineffective in failing to object to the use of evidence about Defendant's silence while being arrested and in not objecting to the manslaughter jury instruction, prejudicing Defendant. The Supreme Court reversed, holding (1) defense counsel was ineffective for not objecting to the manslaughter jury instruction, which incorrectly shifted the burden of proof for imperfect self-defense, but the error was not prejudicial; and (2) assuming that defense counsel was ineffective for failing to object to commentary by the prosecution in Defendant's silence after arrest, the error was not prejudicial.
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