Anthony West v. Mary Berghuis, 16-2438

Background

April 15, 2009: Anthony West shot Brian Garner during a dispute at a Detroit residence; Garner died from a single gunshot wound to the back. Four witnesses (Godboldo, Starks, Skinner, Williams) gave statements; they variably described Garner as the aggressor and West firing three to five shots, some toward the ground and some toward Garner.
West was charged with first-degree premeditated murder, felon-in-possession, and felony firearms; he rejected an early plea offer but later pled guilty to reduced second-degree murder and felony-firearm on October 5, 2009.
At a contentious pretrial hearing defense counsel disclosed that West had tried to influence a witness; counsel expressed skepticism about self-defense, and the relationship had deteriorated.
West sentenced to 20–40 years for murder plus a mandatory consecutive 2-year felony-firearm term.
West filed a 28 U.S.C. § 2254 habeas petition arguing his guilty plea was not knowing and voluntary because trial counsel was ineffective for failing to investigate and for coercing the plea; state courts denied relief and the district court denied habeas; COA was granted solely on counsel-ineffectiveness claim.
The Sixth Circuit reviewed under AEDPA deference and the Strickland / Hill / Lafler framework for ineffective-assistance claims in the plea context.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel rendered constitutionally deficient performance by failing to investigate witness statements and coercing a plea	West: counsel failed to investigate Skinner and Williams, rejecting viable self-defense/accident defenses and pushing plea	State: counsel knew of statements, reasonably judged them unhelpful given autopsy and other witness statements showing West as shooter; advising plea was within professional competence	Denied — counsel's advice to plead was within the range of reasonable professional judgment
Whether West was prejudiced under Strickland/Hill (would have gone to trial and obtained a better outcome)	West: but for counsel's errors he would have insisted on trial and could have obtained acquittal or lesser conviction	State: record shows West sought and accepted a later, better plea; multiple witnesses supported prosecution theory making worse outcome (first-degree murder) likely at trial	Denied — no reasonable probability of better outcome at trial and no showing he would have insisted on trial
Whether the plea was knowing and voluntary given alleged ineffective assistance	West: plea involuntary because based on ineffective counsel	State: Plea colloquy established knowing, voluntary plea; ineffective-assistance claim fails, so plea stands	Denied — plea was knowing and voluntary
Whether the Michigan courts unreasonably applied clearly established federal law under AEDPA	West: state rulings were contrary/unreasonable vis-à-vis Supreme Court precedents (e.g., Tollett, Strickland)	State: Michigan courts reasonably applied Supreme Court precedent; factual findings not unreasonable	Denied — AEDPA deference upheld state-court conclusions

Key Cases Cited

Missouri v. Frye, 566 U.S. 134 (recognizes right to effective assistance during plea bargaining)
Strickland v. Washington, 466 U.S. 668 (two-prong test for ineffective assistance of counsel)
Lafler v. Cooper, 566 U.S. 156 (prejudice standard for plea-related ineffective assistance)
Hill v. Lockhart, 474 U.S. 52 (applying Strickland to guilty pleas; defendant must show he would have gone to trial)
Tollett v. Henderson, 411 U.S. 258 (guilty pleas waive challenge to non-jurisdictional antecedent rights except on counsel effectiveness)
McMann v. Richardson, 397 U.S. 759 (standard for competence of counsel advice in plea context)
Williams v. Taylor, 529 U.S. 362 (unreasonable application standard under AEDPA)
Hand v. Houk, 871 F.3d 390 (6th Cir. standard of review for habeas findings)
Barton v. Warden, S. Ohio Corr. Facility, 786 F.3d 450 (AEDPA limits on federal habeas relief)
Foster v. Wolfenbarger, 687 F.3d 702 (AEDPA deference explained)