United States Supreme Court Cases

 

ELICITING DAMAGING EVIDENCE AND
MAKING DAMAGING ARGUMENT

 

U.S. Court of Appeals Cases

2001: United States v. Villalpando
259 F.3d 934 (8th Cir. 2001)

Counsel ineffective in drug conspiracy and felon in possession of firearms case for eliciting testimony from a government’s witness on cross-examination that the defendant made threats to her and told her that he had ordered a murder. Although the court normally would not address an issue of ineffective assistance of counsel on direct appeal, the court found that this error could not be explained by any possible strategy. Id. at 939. Prejudice found only on drug charges because the defendant stipulated that he was a felon and had admitted on cross-examination that he had possessed the firearms in question

State Cases

2007: People v. Bailey,
___ N.E.2d ___, 2007 WL 1828443 (Ill. App. June 26, 2007).

Counsel ineffective in bench trial for possession of crack with intent to distribute for eliciting damaging evidence in cross-examination. A police officer testified that he observed an “unknown person” yelling “Rocks” to passing cars. When cars stopped, he would direct them to an alley where the defendant would exchange money for drugs. The officer witnessed four such transactions in about 35 minutes before arresting the defendant who had cash and drugs on him. Counsel’s conduct was deficient because during cross counsel elicited further information that the officer witnessed the defendant provide money to the “unknown person” several times and included that information in his case report, which counsel either had not read or did not think about. Counsel’s lack of knowledge of the report, failure to move to strike the officer’s initial non-responsive answer, and “digging the hole deeper” with further questioning was not explicable by any valid trial strategy. Prejudice found because this was “key” evidence in the case and the trial court clearly relied on it and said so.

State v. McCulloch,
733 N.W.2d 586 (Neb. App. 2007).

Counsel ineffective in first degree sexual assault case for introducing evidence of the defendant’s age when the State had failed to establish that he was 19 years of age or older, which was an essential element of the charge against him. Counsel’s conduct was deficient and prejudicial and, because that state’s evidence was insufficient to support a conviction, retrial was barred by double jeopardy.

Robertson v. State,
214 S.W.3d 665 (Tex. App. 2007).

Counsel ineffective in aggravated assault case for eliciting testimony from the defendant that he was incarcerated on two convictions and that he was in possession of a knife at the time of the previous arrests. Prejudice found because this testimony opened the door for the state to elicit testimony on cross-examination that the defendant had two prior drug convictions with “deadly weapon findings on both charges.” The state used this evidence in argument to undermine the defendant’s credibility in arguing self-defense.

2006: Glancy v. State,
941 So. 2d 1201 (Fla. App. 2006).

Counsel ineffective in burglary with a sexual battery case for eliciting damaging character evidence against the defendant. Specifically, counsel’s conduct was deficient for eliciting testimony from the alleged victim that she did not like the defendant because he gave her minor children pot, booze, and cigarettes and because she believed that he had been breaking into her house for two years, stealing her underwear, and leaving “dirty magazines” behind. Counsel also elicited testimony from her son that the alleged victim did not like the defendant because he had been “in and out of prison.” Prejudice found.

Bowers v. State,
929 So. 2d 1199 (Fla. App. 2006).

Counsel ineffective in burglary and grand theft case for questioning the defendant concerning his prior criminal convictions and eliciting numerous details that the State would not have been entitled to elicit since the state's examination would have been limited to the number of felony convictions or convictions for misdemeanors involving dishonesty or false statement. Prejudice found because there was no physical evidence and the trial hinged on credibility issues. By eliciting information concerning prior convictions for burglary and grand theft, trial counsel impugned his client's credibility in front of the jury. While counsel's strategy to be completely candid with the jury so that the defendant's testimony would be more believable, "counsel's execution of the strategy defeated the intent" because the information was presented in such a manner, due to counsel's failure to properly prepare with the defendant, that it appeared the defendant was trying to withhold some information. Thus, the court held "that counsel's strategy to bolster his client's credibility with candor was ‘patently unreasonable.'"

2005: Whitaker v. State
622 S.E.2d 916 (Ga. App. 2005)

Counsel ineffective in burglary case for introducing an unredacted copy of previous convictions for two of the state’s key witnesses that also showed that the defendant had been charged with the same crimes (possession of tools for the commission of a crime, criminal trespass, and burglary). Counsel’s conduct was deficient and not explained simply by counsel’s strategy to impeach the witnesses. Counsel “did not offer any explanation for failing to redact the exhibits, which she knew implicated her client in other crimes.” Prejudice found because the state’s case rested primarily on the testimony of these two alleged accomplices. The evidence showing that the defendant had been previously charged along with these witnesses was especially damaging because it “may have caused the jury to give additional credence to the testimony of the state’s star witnesses.”

People v. Orta
836 N.E.2d 811 (Ill. App. 2005)

Counsel ineffective in bench trial for possession of drugs with intent to deliver drugs case for eliciting testimony from police officers that enabled the State to prove an essential element of the charge. Counsel’s conduct was deficient because counsel elicited information that a prior “control transaction” in which the defendant sold drugs to an informant, over the state’s objection. Counsel also elicited testimony that there were a lot of male clothes in the apartment (when the defendant’s argument was that he had no control or possession) and the drugs were found in a shaving bag, along with money, a scale, and the defendant’s mail, which the state later attempted to move into evidence. Counsel’s conduct was deficient. “A person charged with a crime has the right to expect his lawyer’s questions to prosecution witnesses will not help the State prove its accusations.” Prejudice found primarily because counsel elicited testimony about the prior “control transaction” with the state objecting and the trial court trying to discourage counsel from presenting this evidence. Counsel’s reason for offering this evidence was because he was attacking the officer’s credibility. The court rejected this as a valid strategy. This evidence was prejudicial because the court relied on it in finding an intent to deliver. The evidence about the clothes was also prejudicial because the court relied on it in finding constructive possession. Without all of the evidence elicited by the defense counsel the state’s case for possession was solely that the defendant had keys to the apartment where the drugs were found.

2004: State v. Barr
814 N.E.2d 79 (Ohio Ct. App. 2004)

Counsel was ineffective in fleeing and eluding case for opening the door in cross-examination of a police officer to admission of the defendant’s statements that had previously been suppressed as involuntary. Prejudice found because without the statements there was no evidence the defendant knew he was being followed by police.

State v. Davis
872 So. 2d 250 (Fla. 2004)

Counsel ineffective in capital case for his statements during voir dire expressing racial animus and admitting his own racial prejudice where the Defendant, an African-American male who was 22 at the time, was accused of stabbing to death a 73-year-old white woman, but there was no apparent racial motivation for the crime. During voir dire counsel stated, ASometimes I just don't like black people. Sometimes black people make me mad just because they're black.@ In closing in sentencing, counsel reminded the jurors that none had expressed the same feelings and that they promised not to consider race. Counsel=s strategy in making the comments was to get the jurors to "drop the mask" and acknowledge hidden feelings about race. The court found that Aan explicit expression of racial prejudice can[not] be considered a legitimate tactical approach. Whether or not counsel is in fact a racist, his expressions of prejudice against African-Americans cannot be tolerated.@ Prejudice was found because Athe expressions of racial animus voiced by trial counsel@ would have Aunnecessarily tended either to alienate jurors who did not share his animus against African Americans . . .or to legitimize racial prejudice without accomplishing counsel's stated objective of bringing latent bias out into the open.@ Counsel=s expressions of racial bias also may have affected his performance in both the guilt and penalty phases of trial. In the guilt phase, trial counsel rested without presenting a case, rather than present two African-American witnesses whose testimony would have implicated others in the murder because another white witness would contradict their testimony and counsel found the white witness to be more credible. The trial court also found counsel to be ineffective in sentencing for failing to obtain records and witnesses and never visiting the Defendant=s family or neighborhood.

*People v. Morris
807 N.E.2d 377 (Ill. 2004).

Counsel ineffective in capital case for discussing in great detail an unrelated murder committed by the defendant in opening, even though the trial court had previously agreed to exclude all evidence of the unrelated murder from trial. Defendant was charged, along with several codefendants, with the robbery and murder in Chicago of someone believed to be a drug dealer. Several days before, the defendant had killed a man in a drug-deal gone bad scenario. In opening counsel conceded the defendant=s participation in the charged crimes and discussed the unrelated murder in great detail. The defendant subsequently testified with respect to his involvement in both murders and the state offered evidence on both. In closing argument, the State repeatedly reminded the jury of the unrelated murder. Counsel conceded guilt in opening because her strategy was to minimize the defendant's culpability and essentially plead for jury nullification. While this was a proper strategy, in light of the significant evidence against the defendant, the problem in this case is that counsel also conceded guilt to an unrelated murder that had been excluded from the state=s case prior to trial. Counsel did so because she misunderstood the court=s pretrial ruling to allow the state to use this evidence in rebuttal. Likewise, the defendant=s acquiescence was immaterial because it was undoubtedly based on the same misunderstanding. Thus, counsel=s actions Awere not the product of an informed, strategic choice. Rather, these actions were the product of a mistaken belief that the trial court had ruled evidence of the [unrelated] murder admissible at trial when, in fact, the trial court had ruled just the opposite.@ Prejudice was found because of the Asevere repercussions at trial.@ First, counsel=s jury nullification strategy was dependent on the jury sympathizing with the defendant to some extent. This strategy was completely destroyed by evidence of the defendant=s guilt of the unrelated murder committed just 36 hours before the charged offense. Thus, counsel=s actions Aeviscerated the minimal trial strategy that was available to her.@ ACounsel's deficiencies in this case are distinguishable from typical trial error >not [in] degree but [in] kind.= Bell v. Cone, 535 U.S. 685, ----, 122 S.Ct. 1843, 1851, 152 L.Ed.2d 914, 928 (2002). For in all practical effect, as a result of defense counsel's actions, defendant stood before the jury throughout the trial with no defensive strategy whatsoever.@

2003: Emilio v. State
588 S.E.2d 797 (Ga. Ct. App. 2003)  

Counsel was ineffective in drug trafficking case for admitting evidence of bad character. The defendant and his girlfriend had been arrested following a traffic stop for drugs found in the car. The girlfriend, who had been driving, pled guilty to a lesser offense and testified at the defendant’s trial. During cross-examination of her, counsel offered into evidence a letter the girlfriend had written the defendant, which revealed that the girlfriend had asked the defendant to commit a crime, but also included a statement that the defendant was wanted in five different states. Counsel was ineffective for failing to redact the damaging portions of the letter or to even inform the jury that the defendant was not actually wanted in five states. Counsel’s conduct was prejudicial because the bad character evidence created a reasonable probability that the outcome would have been different since the evidence of the defendant’s guilt was not overwhelming.

2002: Chatmon v. United States
801 A.2d 92 (D.C. 2002)

Counsel ineffective in armed robbery and murder case for eliciting testimony concerning a prior identification of the defendant which had been suppressed prior to trial. Evidence consisted of testimony of a co-defendant who had entered a plea agreement in exchange for testimony and several other witnesses. The co-defendant identified the defendant as the shooter. One eyewitness was unable to identify. The defendant the other eyewitness had tentatively identified the defendant from a photographic lineup but qualified the identification by saying that the robber had longer hair than the person in the picture. At a pretrial hearing, the witness was unable to identify the defendant and the prosecutor agreed not to ask for an in-court identification. The identification from the photo line-up was excluded because the array was unduly suggestive. The prosecutor also agreed not to use the defendant’s statement to police that he had gotten a haircut a few days after the murder because without identification from the photo line-up it was not relevant. While excluding the evidence, the trial court warned counsel not to open the door. During testimony from a detective, counsel asked if he tried to have anyone identify the defendant or co-defendant as the robbers. The detective stated that he could not recall and counsel asked him to review his police reports to refresh his memory. The detective then testified that the eyewitness identified the defendant. Counsel then elicited testimony that the witness had qualified the identification by stating that the robber had longer hair. The state, without objection from the defense, then questioned the detective about the identification. The detective stated that the eyewitness "immediately selected" the defendant and co-defendant from the photo array. The court then sua sponte interrupted the redirect and called the attorneys to the bench. Counsel then objected to the admission of the defendant’s statement about the haircut, but the court overruled the objection because counsel had opened the door. The prosecutor then elicited testimony from the detective that the defendant stated he had gotten a haircut the day after the murder. Following the claim of ineffective assistance, counsel stated that his strategy was to show that no one other then the co-defendant could identify the defendant. Counsel stated that as part of this strategy, he asked the detective whether anyone else had identified the defendant because counsel believed that the eyewitness statement was not a positive identification, but the detective testified that the eyewitness identified the defendant. Counsel stated that he then attempted to impeach the detective with the eyewitness statement that he was unsure because of the robber’s hair length. The appellate court initially addressed the threshold question of whether the court is bound by defense counsel’s actual statements of strategy or whether the court could consider that there was any reasonable strategy to explain counsel’s actions. The court held that "once the record establishes the actual tactical explanation for counsel’s actions, the government is not free to invent a better-reasoned explanation of it’s own." Id. at108-09. The court found deficient conduct because counsel’s strategy made no sense and in the introduction of the prior identification eviscerated the defense strategy. Court rejected the government’s argument that counsel could not have anticipated the testimony that the eyewitness immediately identified the defendant. This argument violates a cardinal rule of examination – "if the defense counsel did not know what [the witness] would say, he should not have asked." Id. at 109. The court also found that counsel was aware of the testimony that would be elicited. The defense counsel’s introduction of a prior identification in light of the expressed strategy of the defense was "simply illogical and could only be counterproductive." The court also found prejudice because without the prior identification counsel could have argued that the government’s case rested solely on the testimony of the co-defendant who had a significant incentive to lie. The court rejected government argument of no prejudice because defense counsel argued that the detective was over Zealous in focusing the investigation on the defendant and perhaps had even lied about defendant statement about the haircut. The court noted that the arguments "were not part of a defense strategy as much as they were necessary to contain the, damage done by counsel’s mistakes." Id. at 111. The court also noted that while the eyewitness identification was initially tentative, the jury could have perceived this as a mark of his scrupulousness. In addition, however tentative the identification was, it was corroborated by the defendant statement that he had a haircut. Finally, the court noted that the state focused on the eyewitness identification during both its closing and rebuttal argument. The court concluded that without the prior identification evidence there is a reasonable probability that the jury would have had a reasonable doubt as to defendant’s guilt. The court also discussed, in a lengthy footnote, counsel’s failure to object to graphic photographs of the body or to at least try to limit their use. The court noted that the photographs introduced in this case were nether independently relevant or corroborative of other evidence during closing argument and the closing rebuttal argument. The government attorney also improperly showed each juror an enlarged photograph of the body while arguing that the jury should reach a verdict that it could live with. The trial court sua sponte noted that the prosecutor’s display of the photographs was not relevant to any issue and was improper. The defense counsel did not object or request an appropriate curative instruction. The court declined to evaluate prejudice from these errors because reversal was already required due to counsel’s introduction to the prior identification.

People v. Fletcher
780 N.E.2d 365 (Ill. App. Ct. 2002)

Counsel was ineffective in vehicular burglary and theft case for asking the defendant to disclose his entire criminal history to the jury when much of the history wad inadmissable otherwise. The state’s case rested almost entirely on the testimony of three accomplices who were arrested in possession of the stolen items but not charged with any offense. The defendant also testified and claimed that he was a witness to the state’s witnesses committing the burglary. Counsel then elicited testimony from the defendant about his extensive criminal history. On cross-examination the state elicited even more information and detail. The defendant’s history included repeated bouts with underage drinking, numerous episodes of trampling state property, two uninvited entries into other people’s homes, misdemeanor thefts from a gas station and a liquor store, a car theft at the age of 14, and obstructing police. The appellate court held that none of this evidence was admissible with the exception of possibly the defendant’s misdemeanor theft convictions and the state’s cross-examination about those offenses would have been limited if defense counsel had acted appropriately. Instead the defendant was cross-examined extensively that he had actually committed felony offenses, but escaped conviction solely due to plea bargaining. Deficient conduct found because "[n]o reasonable defense lawyer would ask his client to tell the jury about an extensive history of criminality and have the client readily admit that he was guilty on every occasion, in order to convince the jury that he is innocent of a like crime because he denies his guilt instead of pleading guilty." The court also found deficient conduct because if counsel had filed a motion in limine prior to calling his client to the stand the trial court may well have prohibited cross-examination on the misdemeanor convictions as well because the probative value is outweighed but the undue prejudice. Prejudice found because all of the state’s evidence of guilt was evidence that needed to be viewed with great caution. The court also noted that the defendant was charged with burglary and theft and that if the jury had taken the state’s witnesses at their word they would have convicted on both offenses. Instead the jury convicted only on the theft offense.

People v. Jackson
741 N.E.2d 1026 (Ill. App. Ct. 2000)

Counsel ineffective in possession of controlled substance case for eliciting the only evidence that connected the defendant to the crime. The state's only evidence was the testimony of a police officer that testified he observed the defendant receive money from an unknown person and point to a third person. The third person then walked over to unknown person and then left scene. The unknown person had a bag on him that contained crack cocaine and heroin. During cross, the defense elicited testimony for the first time that the unknown person reached into the paper bag and transferred an object to the unknown person before he left, which was the only link between the defendant and the contraband. Prejudice found because without this evidence the state could not have obtained a conviction.

Caprood v. State,
338 S.C. 103, 525 S.E.2d 514 (2000)

Counsel ineffective in armed robbery case for eliciting hearsay from officer about the defendant's "rap sheet" and "some type of violation" previously. Trial court had found ineffective and granted relief on a number of bases. Supreme Court reversed on all but this one, because the state had not appealed on this issue and the trial court's ruling was thus the law of the case.

1999: People v. Young
716 N.E.2d 312 (Ill. App. Ct. 1999)

Counsel in aggravated battery case ineffective in bench trial for eliciting otherwise inadmissible evidence that the shooting victim had made 14 prior consistent statements identifying the defendant as the shooter.

1998: State v. Saunders
958 P.2d 364 (Wash. Ct. App. 1998)

Counsel ineffective in drug possession case for eliciting defendant's prior possession conviction during direct examination. Evidence was probably inadmissible because prior drug convictions are generally not probative of a witness's veracity and because the conviction was more prejudicial than probative since it shifted the focus to the defendant's propensity for drug possession when his defense was that the possession was unwitting (not his car).

1992: People v. Phillips
592 N.E.2d 233 (Ill. App. Ct. 1992)

Counsel ineffective for eliciting hearsay from detective on cross-examination regarding defendant's prior criminal record where the only evidence of armed robbery was the victim's weak identification.

1990: People v. Salgado
558 N.E.2d 271 (Ill. App. Ct. 1990)

Counsel ineffective in burglary case for calling defendant as a witness and eliciting a confession during direct examination where the trial judge indicated he would have found the defendant guilty of only the lesser included offense of theft but for the defendant's admissions.

1986: State v. Smith
712 P.2d 496 (Haw. 1986)

Trial counsel ineffective for referring to defendant's prior convictions and incarcerations and other lewd conduct and eliciting from defendant during direct examination in prosecution for attempted sodomy where the success of the asserted defense that defendant was merely exposing himself hinged on defendant's credibility.

State v. Dornbusch
384 N.W.2d 682 (S.D. 1986)

Counsel ineffective in burglary case where state's evidence was only circumstantial for eliciting the victim's testimony that he suspected the defendant of having committed a previous theft and for asking detective if he asked defendant to take polygraph which opened the door to presentation of evidence that defendant refused to take polygraph.

1985: Kornegay v. State
329 S.E.2d 601 (Ga. Ct. App. 1985)

Trial counsel's closing argument in interracial rape case in which he referred to defendants as "niggers" and said they would have been lynched for the same conduct 40-50 years ago injected race into the case and allowed jury to consider race.