In re Champion, 170 Cal. Rptr. 3d 211

Champion seeks habeas corpus relief from a 1982 death judgement in Los Angeles County, after affirmations on direct appeal and a 2002 OSC related to alleged ineffective penalty-phase representation.
The case featured multiple murders tied to drug dealing in South Central Los Angeles and evidence the prosecution framed as gang-related Raymond Avenue Crips activity.
At penalty, the prosecution presented prior juvenile felonies and other murders; defense offered limited mitigation via two witnesses (mother and parole officer).
A referee conducted a comprehensive factual investigation into defense counsel Skyers' penalty-phase investigation and the credibility of posttrial witnesses.
The referee found Skyers did not adequately conduct an independent penalty-phase investigation and failed to retain a penalty-phase investigator, but also found much of the introduced evidence unlikely to alter the outcome.
The California Supreme Court concluded that Skyers’ performance did not prejudice Champion, and discharged the order to show cause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Skyers' penalty-phase representation meet objective standards?	Skyers failed to conduct independent mitigation investigation.	Skyers reviewed discovery, visited scenes, interviewed petitioner, and pursued reasonable mitigation efforts under 1982 norms.	No prejudice; not below standard; no reasonable probability of different outcome.
Could additional mitigating evidence have changed the penalty phase result?	Additional evidence (family history, brain injury, alibi, social history) would have influenced the jury.	Evidence was not credible or would have been countered by prosecution; alibi and social history would not have changed result.	Not likely to alter the death sentence; no prejudice shown.
Would any family nondisclosure or witness credibility issues undermine the Strickland analysis?	Family nondisclosure denied access to mitigating evidence; alibi witnesses were credible and would have helped.	Referee credibility determinations were proper; non-disclosures did not establish ineffective assistance.	No prejudice; nondisclosure did not negate effective assistance.

In re Champion, 9 Cal.4th 879 (Cal. 1995) (direct appeal (Champion) background in this habeas context)
People v. Ross, 10 Cal.4th 184 (Cal. 1995) (codefendant's ineffective assistance framework and prejudice considerations)
Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court, 1984) (standard for ineffective assistance: deficient performance plus prejudice)
In re Lucas, 33 Cal.4th 682 (Cal. 2004) (duty to explain the standard for reasonable investigation in capital cases)
People v. Bassett, 69 Cal.2d 122 (Cal. 1968) (reliability considerations for psychiatrists testifying on diminished capacity)