Eleventh Circuit Court of Appeals - Published Opinions

Thursday, August 03, 2006

Williams: No Ineffectiveness of Counsel

In Williams v. Allen, No. 05-12691 (Aug. 2, 2006), the Court affirmed the denial of habeas relief to a defendant sentenced to death for a 1988 murder.
The Court rejected the argument that Williams received ineffective assistance of counsel because counsel failed to review a file before trial. The Court found that no prejudice resulted from this, as the file would not have helped Williams sustain a relevancy objection to incriminating evidence.
The Court also rejected the argument that counsel was ineffective for failing to investigate mitigating evidence for use at sentencing. The pertinent information was in fact presented, and any deficiency did not undermine confidence in the outcome of the case.
Finally, the Court rejected the argument that counsel failed to investigate "reasonable doubt" as to whether Williams committed murder. The Court found that the theories of defense were adequately investigated, and any failure did not prejudice Williams.