Edwards v. Commissioner of Correction, 141 Conn. App. 430

Edwards shot the victim after a confrontation outside a Hartford store; the victim died from a gunshot wound the next day.
Evidence included an alias statement by a bar bouncer, Davis, describing the incident and potential gun sales; at a bond hearing, counsel noted the alias.
At trial, Edwards testified he did not pull the trigger, claiming accidental discharge while attempting to disarm the victim, and he admitted giving the gun to Ford.
The state relied on Davis’ signed statement to impeach Edwards; several witnesses placed Edwards at the scene and in proximity to the shooting.
Edwards petitioned for habeas corpus alleging ineffective assistance of trial counsel and later alleged ineffective assistance by his first habeas counsel for not raising certain claims.
The second habeas court ruled against Edwards on the prosecutorial impropriety claim and found no prejudice from any claimed ineffective assistance; certification to appeal was granted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was prior habeas counsel ineffective for not raising the prosecutorial-impropriety claim?	Edwards contends Brooks was ineffective for failing to raise it.	State argues no deficiency and no prejudice since claim meritless.	No ineffective assistance; claim would fail on the merits.
Did Murphy commit prosecutorial impropriety by cross-examining with Davis’ alias-based statement?	Edwards argues the alias rendered the cross-examination improper and unreliable.	Murphy had a good faith basis and corroboration supported questioning.	Not prosecutorial impropriety; questioning permissible.
If prosecutorial impropriety occurred, did it violate due process?	Edwards asserts the cross-examination infected the trial with unfairness.	The court would consider due process in light of entire trial; no impropriety found.	Not reached due to absence of prosecutorial impropriety.
Was the Strickland standard properly applied to assess ineffective assistance of habeas counsel?	Edwards contends the standard requires showing both ineffectiveness and prejudice.	State argues the two-prong Strickland test applies and was not satisfied.	Strickland analysis applied; Edwards failed to prove both prongs.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
Lozada v. Warden, 223 Conn. 834 (1992) (reiterates Lozada framework for ineffective habeas claims)
Lapointe v. Commissioner of Correction, 113 Conn. App. 378 (2009) (highly deferential review of counsel's performance)
State v. Souza, 125 Conn. App. 529 (2010) (context for prosecutorial impropriety analysis and due process considerations)
State v. Alexander, 254 Conn. 290 (2000) (impeachment standards for witness credibility and cross-examination)
State v. Barnes, 232 Conn. 740 (1995) (good faith basis required for cross-examination referencing prior statements)
Perry v. Leeke, 488 U.S. 272 (U.S. 1989) (defendant-on-the-stand credibility and limitations of impeachment)