Rainwater Law Group

Effective Criminal Defense

Medina v. Chappell, No. 09-99015 [March 26, 2015 & April 16, 2015]

(First part dealing with a pre-ADEPA case) Medina claimed that his trial counsel was ineffective for failing to properly investigate Medina childhood, which meant that counsel lacked information that court have been used in mitigation at the penalty phase. The court found the investigation was adequate when compared to investigations in other cases, that counsel does not have a duty to conduct a perfect investigation and that Medina failed to establish prejudice as the comparatively weak additional mitigating evidence would not likely have altered the jury's verdict. In the alternative, he argued that counsel was ineffective for failing to obtain and present evidence of his mental and emotional impairments. The court found no deficient performance because counsel efforts were reasonable at the time. Finally, the court denied a stay due to Medina's incompetency finding no right to a stay in habeas proceedings and given the court's limited discretion where "there is no reasonable hope of a petitioner regaining competence in the foreseeable future. (Second part dealing with ADEPA) Finding the state court findings to reasonable or that the error was harmless.
[* The court ordered the parties to file briefs on what to do with the opinion in light of Medina's death after the opinion was written, but before it was filed. Stating "we direct the parties to file letter briefs within 14 days hereof addressing how best to proceed with the opinion in light of Mr. Medina’s death."] Update: [April 16, 2015] the Court issued the following order: "In light of Petitioner’s death, we vacate the opinion filed March 26, 2015 as moot, and remand to the district court with instructions to dismiss the habeas petitions."
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