Deadrick Garrett v. State of Tennessee, E2016-01519-CCA-R3-PC

Background

Petitioner Deadrick Garrett was convicted by a jury of first-degree premeditated murder for stabbing his half-brother; sentenced to life imprisonment. He admitted going to the victim’s home armed and later gave recorded statements admitting the killing and efforts to conceal evidence.
At trial Garrett claimed the victim had sexually assaulted Garrett’s sister and testified to a version of events in which the victim was aggressive; the trial court refused a self-defense instruction.
Post-conviction petition alleged ineffective assistance of trial counsel across multiple grounds (poor communication, failure to review discovery, failure to obtain mental-health evaluation/diminished-capacity theory, failure to prepare alternative defenses, failure to object to a courtroom knife demonstration, advising witnesses to be hostile, coaching Garrett to “cry on cue,” and fabricating Garrett’s testimony).
At the evidentiary hearing the State’s longtime ADA testified trial counsel had vigorously defended the case, sought manslaughter/self-defense theories, filed motions, investigated, and prepared Garrett for testimony; she viewed first-degree proof as strong.
The post-conviction court credited the State’s witness, found trial strategy reasonable, and concluded Garrett failed to prove deficient performance or resulting prejudice under Strickland.
The Court of Criminal Appeals affirmed, holding Garrett did not meet his burden to show counsel was deficient or that any deficiency prejudiced the outcome given the overwhelming proof of guilt.

Issues

Issue	Garrett's Argument	State's Argument	Held
Failure to communicate/explain procedure	Trial counsel didn’t adequately explain criminal/trial process	Counsel visited often, discussed strategy, and prepared Garrett	Denied — no deficient performance or prejudice
Failure to review discovery	Counsel didn’t review discovery with Garrett	Garrett couldn’t show how this prejudiced him	Denied — no prejudice established
Failure to obtain mental evaluation / pursue diminished-capacity	Counsel should have ordered psychological testing and presented diminished-capacity expert	No medical proof presented at hearing to support diminished capacity	Denied — petitioner failed to prove prejudice
Failure to anticipate denial of self-defense instruction / prepare alternative	Counsel should have prepared another viable defense if self-defense was refused	Counsel pursued manslaughter/self-defense theory focused on victim’s alleged conduct; strategy reasonable	Denied — tactical choice was reasonable
Failure to object to knife demonstration	Counsel should’ve objected when prosecutor had Garrett demonstrate opening the knife	Demonstration supported Garrett’s heat-of-passion account; no prejudice	Denied — no prejudice shown
Coaching witness to be hostile (mother)	Counsel told mother to testify she didn’t like victim, contrary to her experience	Even if suggested, petitioner failed to show resulting prejudice	Denied — no prejudice established
Coaching Garrett to “cry on cue”	Counsel instructed Garrett to cry to add emotional weight	Garrett still testified coherently; State’s witness said he was composed and well-prepared	Denied — no prejudice shown
Fabrication of Garrett’s trial testimony	Counsel fabricated defensive facts to justify stabbing	Much of Garrett’s trial story mirrored his pretrial admissions; overwhelming evidence of guilt	Denied — no reasonable probability of different outcome

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (constitutional standard for ineffective assistance of counsel)
Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (counsel effective if within range of competence; deference to tactical choices)
Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (prejudice prong: reasonable probability of different result required)
Black v. State, 794 S.W.2d 752 (Tenn. Crim. App. 1990) (witnesses supporting omitted defenses must be presented at evidentiary hearing)
Jaco v. State, 120 S.W.3d 828 (Tenn. 2003) (post-conviction petitioner must prove factual allegations by clear and convincing evidence)