Alexis Mason v. State of Tennessee, W2015-01644-CCA-R3-PC

Alexis Mason was convicted by a Shelby County jury of second-degree murder (lesser included) and three counts of aggravated assault for a 2009 drive-by shooting that killed Sabrina Campbell; she received an effective 37-year sentence.
Prosecution witnesses placed Mason in the passenger seat of a black SUV who brandished a gun and fired into a car carrying the victims; ballistics linked recovered bullets to the same gun.
Mason’s trial counsel pursued a misidentification defense, asserting Mason was not present; Mason did not testify and counsel sought severance when co-defendant’s attorney suggested Mason’s presence via a self-defense theory.
On direct appeal, convictions and sentence were affirmed and Tennessee Supreme Court denied review.
Mason filed a post-conviction petition arguing trial counsel was ineffective for failing to present/request a jury instruction on self-defense; the post-conviction court denied relief, finding counsel’s choice was a reasonable tactical decision and Mason had not shown deficient performance or prejudice.
This appeal affirms the post-conviction court: the court held counsel’s choice to pursue misidentification over self-defense was a permissible trial strategy and not constitutionally deficient.

Issue	Mason's Argument	State's Argument	Held
Whether trial counsel was ineffective for failing to present/request a self-defense instruction	Counsel should have raised self-defense because evidence raised that issue and the jury might have acquitted	Counsel reasonably pursued a misidentification defense; self-defense and misidentification are inconsistent and counsel’s strategy was reasonable	Denied — counsel’s choice to pursue misidentification was a reasonable tactical decision; no deficient performance shown

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective assistance standard: deficiency and prejudice)
Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (review of counsel performance: deference to tactical decisions)
Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (clarifies objective standard for deficient performance)
Felts v. State, 354 S.W.3d 266 (Tenn. 2011) (counsel need not pursue inconsistent defenses)
Jaco v. State, 120 S.W.3d 828 (Tenn. 2003) (post-conviction burden: proof by clear and convincing evidence)
Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (appellate review of mixed questions of law and fact in post-conviction cases)
Baxter v. Rose, 523 S.W.2d 930 (Tenn. 1975) (competence standard for counsel in criminal cases)