Law School Case Brief
Carpenter v. United States - No. 2:13-cv-08043-LSC-JHE, 2016 U.S. Dist. LEXIS 128956 (N.D. Ala. Aug. 5, 2016)
The Supreme Court established a two-prong test a movant must show for ineffective assistance of counsel, namely: (1) the attorney's performance was deficient; and (2) the movant was prejudiced by the deficient performance.
Carpenter was charged in a 55-count superseding indictment, along with 15 other individuals. He was found guilty of one count of conspiracy to distribute or possess with intent to distribute 500 grams of cocaine hydrochloride and 50 grams or more of cocaine base and one count of distribution of cocaine hydrochloride and distribution of 50 grams or more of cocaine base. He was sentenced on January 29, 2009, to a term of life imprisonment. On appeal, Carpenter asserted (1) he was prejudiced by the admission of undisclosed prior bad acts evidence; (2) he was convicted of participating in a drug conspiracy on insufficient evidence; and (3) his life sentence violated the Eighth Amendment. The appellate court affirmed his conviction despite all his grounds. Carpenter, iwho s incarcerated at USP Pollock, in Pollock, Louisiana filed this Motion to Vacate, Set Aside, or Correct a Sentence pursuant to 28 U.S.C. § 2255. In accordance with the usual practices of the district court, the § 2255 motion was referred to the magistrate for preliminary review and recommendation.
Was Carpenter denied his right to effective assistance of counsel?
The magistrate recommended that Carpenter's Motion to Vacate, Set Aside or Correct Sentence be denied with prejudice. In Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984), the United States Supreme Court established a two-prong test a movant must show for ineffective assistance of counsel, namely: (1) the attorney's performance was deficient; and (2) the movant was prejudiced by the deficient performance. The first prong, performance, requires a showing that the attorney's representation fell below an "objective standard of reasonableness." The second requisite, the "prejudice prong," requires a showing that the outcome of the case would have been different but for the attorney's errors. Even if counsel made an error so egregious as to be outside the broad scope of competence expected of attorneys, a movant can obtain relief only if the error caused actual prejudice. The magistrate applied this standard to each of Carpenter's 10 claims of ineffective assistance of counsel and found that all claims did not comply with this standard.
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