Eric Bledsoe v. State of Tennessee, W2016-00419-CCA-R3-PC

Eric Bledsoe was convicted by a Shelby County jury (April 2012) of aggravated rape, aggravated burglary, and theft; sentenced to an effective 65 years; conviction affirmed on direct appeal.
Victim testified she awoke to an intruder in her bedroom, was choked unconscious, later found her underwear disarranged and her Jeep stolen; DNA from underwear and latent prints matched Bledsoe; Bledsoe gave a statement admitting intercourse and taking the vehicle.
Bledsoe filed a post-conviction petition alleging ineffective assistance of trial counsel for (1) failing to call defense witnesses to show a prior relationship with the victim and (2) failing to investigate/present his mental-health history.
At the post-conviction evidentiary hearing, Bledsoe testified about prior relationships, substance use, and psychiatric diagnoses; trial counsel testified he investigated, visited Bledsoe multiple times, sought mental-health evaluations, and pursued a theory that there was no proof of penetration.
Post-conviction court found Bledsoe’s proffered witnesses offered little credible or admissible impeachment value and that, weighed against strong physical and testimonial evidence (DNA, fingerprints, consistent victim statements, Bledsoe’s own statement), Bledsoe failed to show prejudice from counsel’s choices.
The Court of Criminal Appeals affirmed, applying Strickland prejudice analysis and deferring to the post-conviction court’s credibility findings.

Issue	Petitioner’s Argument	State’s Argument	Held
Whether trial counsel was ineffective for not calling witnesses to show a prior relationship with the victim	Bledsoe: counsel ignored his requests to subpoena witnesses (mother, brother, Veronica White) who would show he knew the victim and impeach her credibility	State: post-conviction court found Bledsoe and his witnesses not credible; testimony would have limited probative value and some would be inadmissible hearsay; no prejudice shown	Denied — counsel’s performance not shown to be prejudicial; post-conviction credibility findings upheld
Whether counsel failed to adequately investigate or present Bledsoe’s mental-health history to explain his confession	Bledsoe: had diagnoses and was off medications; mental illness could explain confession and impaired capacity	State: issue inadequately developed on appeal; on record counsel sought evaluations and was informed Bledsoe was competent; no proof of prejudice	Denied — claim waived for lack of developed argument and petitioner failed to show prejudice

Strickland v. Washington, 466 U.S. 668 (establishes two-prong test for ineffective assistance of counsel)
Lockhart v. Fretwell, 506 U.S. 364 (prejudice analysis under Strickland)
Dellinger v. State, 279 S.W.3d 282 (Tenn. 2009) (post-conviction burden and review principles)
Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (deference to trial court on factual findings and credibility)
Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (both prongs required to prevail on ineffective-assistance claim)
Melson v. State, 772 S.W.2d 417 (Tenn. 1989) (Strickland applied under Tennessee Constitution)
Black v. State, 794 S.W.2d 752 (Tenn. Crim. App. 1990) (petitioner must ordinarily produce missing witness at evidentiary hearing to prove prejudice)
Cooper v. State, 847 S.W.2d 521 (Tenn. Crim. App. 1992) (failed tactics alone do not establish ineffective assistance)
Hellard v. State, 629 S.W.2d 4 (Tenn. 1982) (strategic choices afforded deference if based on adequate preparation)