Couch v. Booker
2011 U.S. App. LEXIS 2105
| 6th Cir. | 2011Background
- Daniel Couch was convicted by a Michigan jury of second-degree murder and sentenced to 19-to-40 years' imprisonment.
- Couch petitioned for habeas relief claiming ineffective assistance of counsel and violation of his right to counsel of choice.
- The district court granted the writ after an evidentiary hearing, finding ineffective assistance for failure to investigate a causation defense.
- Michigan courts rejected the ineffective-assistance claim; the state post-conviction proceedings did not revisit the issue.
- The core dispute centered on whether trial counsel failed to investigate a causation defense that could have altered the outcome.
- Key evidentiary facts included an autopsy, toxicology, and a fire department report suggesting alternative causation and challenging the State’s drowning-in-blood theory.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel's investigation was constitutionally deficient. | Couch | Couch | Yes; failure to pursue a readily available causation defense was deficient |
| Whether Couch was prejudiced by counsel's deficient performance. | Couch | Couch | Yes; there is a reasonable probability of a different outcome |
| Whether the district court properly held an evidentiary hearing under §2254(e)(2). | Couch | State | District court did not abuse discretion; evidentiary hearing warranted |
| Whether the failure to pursue the causation theory violated Couch's right to counsel of choice. | Couch | State | Not reached; district court ruling on ineffective assistance controls |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance)
- Rompilla v. Beard, 545 U.S. 374 (2005) (failure to obtain and investigate prior conviction evidence as prejudice)
- Wiggins v. Smith, 539 U.S. 510 (2003) (mitigation evidence and prejudice from limited investigation)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (deferential standard under §2254(d) emphasis on reasonable basis for denial)
- Williams v. Coyle, 260 F.3d 684 (2001) (diligence in presenting claims and state-court review)
- Brown v. Smith, 551 F.3d 424 (2008) (fresh evidence and standard for applying §2254(d))
- Bigelow v. Haviland, 576 F.3d 284 (2009) (duty to investigate plausible defense options)
- Campbell v. Coyle, 260 F.3d 531 (2001) (expert reliance in defense strategy does not relieve discovery duty)