Eric Clark v. James Arnold
2014 U.S. App. LEXIS 19243
| 9th Cir. | 2014Background
- Clark, a state prisoner, was convicted of first‑degree murder of a police officer in a bench trial.
- He asserted trial counsel was ineffective for failing to preserve observation evidence and for not seeking a competency reevaluation.
- He argued appellate counsel was ineffective for not raising these issues on appeal.
- Clark underwent competency evaluations; multiple doctors initially deemed him competent, though some disagreed.
- Arizona law restricted insanity evidence to moral incapacity and barred evidence negating mens rea except under certain limits; the Mott decision affected admissibility of such evidence.
- The Supreme Court later decided Clark v. Arizona, clarifying limits and observation evidence, and the case proceeded through state post‑conviction and federal habeas proceedings under AEDPA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Observation evidence preservation | Clark | Clark v. Arizona narrowed Mott; counsel could not reasonably preserve broader claim | Not merit, not unreasonable under Strickland |
| Competency reevaluation during trial | Clark’s competency issues persisted; counsel should have sought reevaluation | Record showed competency; reevaluation unlikely to change outcome | Not deficient performance; no reasonable probability of different outcome |
| Appellate counsel effectiveness (default/ Martinez) | Appellate counsel should have raised observational/competency claims | Default bars review; no prejudice shown | procedurally defaulted; affirm denial of habeas petition |
Key Cases Cited
- Clark v. Arizona, 548 U.S. 735 (2006) (established three evidence categories and limited due process challenge to observation evidence)
- Mott v. Stewart, 931 P.2d 1046 (Ariz. 1997) (Arizona’s rule restricting evidence short of insanity to negate mens rea)
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
- Knowles v. Mirzayance, 556 U.S. 111 (2009) (doubly deferential review for Strickland claims in § 2254 cases)
- Martinez v. Ryan, 132 S. Ct. 1309 (2012) (addressed when default rules apply to ineffective‑assistance claims)