Mendoza: Counsel not ineffective in investigating mitigating evidence

In Mendoza v. Sec., Fla. Dept of Corrections, No. 13-14968 (July 31, 2014), the Court affirmed the denial of habeas relief to a Florida inmate sentenced to death for a 1992 murder. The Court rejected the argument that trial counsel performed a deficient investigation of mitigating evidence, noting that counsel “thoroughly” investigated Mendoza’s mental health, and hired three experts to evaluate Mendoza’s mental health. The Court also rejected the argument that the defense should have put on evidence that Mendoza had a substance abuse problem, pointing out that this argument is a “two-edged sword.”