Rainwater Law Group

Effective Criminal Defense

Mann v. Ryan, No. 09-99017 [July 15, 2016]

Mann v. Ryan

After hearing the case en banc the Court affirmed the district court’s denial of Mann’s petition finding no ineffective assistance at the guilt-phase or at sentencing. The Court was presented with the question: When, in the absence of clarity, can this court conclude that a state court has applied the wrong standard to review a Strickland claim raised in a petition for post-conviction relief? The Court held that it must approach this question with the deference AEDPA requires and grant habeas relief only if no fairminded jurist could conclude that the adjudication was consistent with clearly established Supreme Court precedent and that here fairminded jurist could conclude that the state court’s review of Mann’s claim of ineffective assistance of counsel comported with Strickland. Therefore, applying AEDPA deference to his claims the Court found the denial of his claim was not contrary to, or and unreasonable application of, federal law.

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