Velazco: no evidentiary hearing on counsel's ineffectiveness

In Velazco v. Dep’t of Corrections, No. 13-12525 (Dec. 16, 2014), the Court affirmed the denial of an evidentiary hearing to a habeas petitioner who claimed that counsel was ineffective for failing to investigate two defense witnesses to the murder whose credibility was impeached at trial. The Court found that the Florida courts could have reasonably concluded that Velazco failed to establish prejudice regarding his trial counsel’s failure to investigate, because these two witnesses were, in fact, helpful to the defense, and because of the overwhelming evidence that defeated his defense of self-defense.