Edgar v. State
283 P.3d 152
| Kan. | 2012Background
- Edgar challenged his 60-1507 ineffective-assistance claim based on defense counsel conceding guilt on non-felony counts, during closing arguments, while contesting felony murder; district court denied summarily; Court of Appeals remanded for an evidentiary hearing on the prejudice prong; this Court granted review of the prejudice issue and standard-of-review questions.
- Edgar was convicted of felony murder (Brian’s death) and two child-abuse counts; evidence showed conflicting testimony about who restrained or taped Brian; the State argued Edgar aided and abetted, while defense claimed Christy and Boyd were primarily responsible.
- Trial evidence included peers’ testimonies, expert testimony about ligature marks, and closing arguments emphasizing Edgar’s lack of participation while focusing on aiding and abetting by others; the defense strategy foregrounded Edgar’s non-involvement.
- Kansas Supreme Court applied Strickland/Chamberlain and rejected applying the Cronic exception, holding the Court of Appeals should have reviewed prejudice first or de novo on the prejudice prong, and that Edgar failed to show a reasonable probability of a different outcome.
- The Court held there was not a reasonable probability of a different outcome; the evidence was overwhelming and the closing argument did not negate the sufficiency of the case against Edgar; thus district court’s denial of relief was correct.
- The dissent would apply Carter to require new trial if counsel conceded guilt on non-homicide counts, arguing Carter remains good law and the Court should remand for a Carter-based analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prejudice prong was properly addressed | Edgar: prejudice should be assessed; Court of Appeals erred by not analyzing the prejudice prong. | State: prejudice prong adequately analyzed; remand unnecessary. | Prejudice prong properly reviewed; Edgar failed to show a reasonable probability of not guilty on felony murder. |
| Whether Strickland/Chamberlain governs here or Carter/Cronic should apply | Edgar: Carter/Cronic apply to compel a Cronic-like presumption of prejudice. | State: Strickland/Chamberlain governs; no Cronic presumption. | Court reaffirmed Strickland/Chamberlain framework; Carter/Cronic not applied. |
| Was evidentiary hearing required to resolve first-prong issue | Counsel’s closing strategy was a trial tactic; facts require an evidentiary hearing. | Record shows defense strategy; no first-prong factual dispute requiring hearing. | No first-prong remand; record supports summarily denying 60-1507 claim. |
| Standard of review for summary denial of 60-1507 motion | De novo review required to assess prejudice after summary denial. | De novo review appropriate to determine entitlement to relief. | De novo review applied; Court found no prejudice. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court, 1984) (established two-prong test for ineffective assistance of counsel)
- Chamberlain v. State, 236 Kan. 650 (Kan. 1985) (adopted Strickland standard in Kansas)
- Carter, 270 Kan. 426 (Kan. 2000) (Cronic-like prejudice presumption discussed (Carter))
- Nixon v. Bell, 543 U.S. 175 (U.S. 2004) (limits Cronic applicability; Strickland controls in many cases)
- Bell v. Cone, 535 U.S. 685 (U.S. 2002) (attorney failure must be complete for Cronic presumption)
- Bledsoe v. State, 283 Kan. 81 (Kan. 2007) (two-step ineffective-assistance framework; deference to counsel’s strategic decisions)
- Gonzales v. State, 289 Kan. 351 (Kan. 2009) (confirms deference to trial strategy; requires careful analysis of deficiency and prejudice)