Byrd v. Workman, 2011 U.S. App. LEXIS 10678

Byrd, an Oklahoma prisoner with a prior history of seven felonies seeking habitual-offender enhancement, was charged in 2004 with multiple counts including DUI and drug offenses.
Oklahoma law allowed sentence enhancement under § 51.1(B) only if relied convictions were not from the same transaction; bifurcated trial was required for enhancement questions.
At trial, the court initially barred prior-conviction references in phase one; a mistrial occurred when an officer referenced them on direct examination in the first trial.
In a second trial, the State presented its case without reference to prior convictions; Byrd testified and admitted seven convictions, which the State used to impeach and at sentencing, with judgment-and-sentence reports admitted.
On appeal, the Oklahoma Court of Criminal Appeals (OCCA) held that five of the seven convictions arose from two transactions and that only two should have been used for enhancement; it further concluded the remaining conviction introductions were sound trial strategy.
Byrd pursued habeas corpus under 28 U.S.C. § 2254, arguing ineffective assistance of counsel for (a) failing to investigate transactional nature of convictions and (b) introducing all convictions at trial; the district court denied relief and this court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to investigate transactional nature of convictions	Byrd argues counsel failed to identify transactional conflicts that would render convictions inadmissible for enhancement.	Workman contends the OCCA reasonably applied Strickland and found no prejudice despite the potential errors.	No reasonable prejudice established; OCCA reasonably applied Strickland.
Introduction of all prior convictions at trial	Byrd contends eliciting all convictions was ineffective and prejudicial since only some were admissible for enhancement.	Workman asserts trial strategy supported admitting priors to frame Byrd's character and prospects for impeachment.	No prejudice shown; strategy within range of reasonable professional conduct.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (standard for ineffective assistance of counsel; prejudice and performance prongs)
Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (unreasonable application of clearly established law standard under AEDPA)
Woodford v. Visciotti, 537 U.S. 19 (U.S. 2002) (AEDPA deference commitments on state-court rulings)
Maynard v. Boone, 468 F.3d 665 (10th Cir. 2006) (AEDPA deference and standards for prejudice under Strickland)
Wood v. Hargett, 16 F. App'x 886 (10th Cir. 2001) (sentencing prejudice and effect of prior-conviction evidence (non-precedential))
Miller v. State, 675 P.2d 453 (Okla. Crim. App. 1984) (transactional convictions and enhancement admissibility in Oklahoma)
Gipson v. Jordan, 376 F.3d 1193 (10th Cir. 2004) (AEDPA review framework: unreasonable application of federal law)