Barker v. Barrow, 290 Ga. 711

Barker was convicted in 1996 of possession of cocaine with intent to distribute and sentenced to life without parole as a recidivist based on five prior convictions.
In 2008 Barker filed a habeas corpus petition alleging ineffective assistance of trial and appellate counsel regarding the validity of his prior pleas used for sentencing.
Habeas court found Barker proved Boykin rights issues on 1993 and 1994 priors, rendering the 1996 sentence illegal and declined to address other priors or ineffectiveness claims.
This Court vacated and remanded to consider cause-and-prejudice or miscarriage-of-justice standards for defaulted issues and whether counsel was ineffective.
On remand, the habeas court again denied relief, finding no ineffective assistance by trial or appellate counsel.
Georgia Supreme Court affirmed, applying Strickland and deferring to habeas findings on reasonableness of trial counsel's investigation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel's investigation was deficient	Barker contends counsel failed to scrutinize plea transcripts despite notice of enhancement.	Barrow argues counsel reasonably investigated given circumstances and did not need to review every colloquy.	Trial counsel not ineffective; reasonable investigation under circumstances.
Whether Rompilla governs reasonableness here	Rompilla requires retrieval and review of prior conviction files when state intends to enhance sentence.	Rompilla not controlling because facts differ and a rigid duty to examine all files is unwarranted.	Rompilla's heightened duty not imposed; reasonable efforts here were sufficient.
Whether appellate counsel's failure to raise trial-counsel ineffectiveness was ineffective	Appellate counsel should have challenged trial counsel's investigation.	No reversible error since trial counsel was not ineffective.	Appellate counsel not ineffective; no prejudice shown.

Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (counsel must review probable aggravation material when prosecution relies on prior convictions)
Terry v. Jenkins, 280 Ga. 341 (Ga. 2006) (reasonable investigations judged from counsel's perspective with deference to judgments)
Bazemore v. State, 273 Ga. 160 (Ga. 2000) (routine court procedures can show compliance with constitutional standards)
Jackson v. Hopper, 243 Ga. 41 (Ga. 1979) (illustrates consideration of court procedure in evaluating compliance)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
Battles v. Chapman, 269 Ga. 702 (Ga. 1998) (framework for evaluating ineffective assistance claims)
Cammer v. Walker, 290 Ga. 251 (Ga. 2011) (standard for reviewing habeas determinations of counsel effectiveness)
Chatman v. Mancill, 278 Ga. 488 (Ga. 2004) (procedural-default considerations in habeas claims)
Walker v. Hagins, 290 Ga. 512 (Ga. 2012) (affirmations of habeas court factual findings unless clearly erroneous)