James M. Manley v. State of Maine, 123 A.3d 219

James M. Manley was indicted for elevated aggravated assault and related charges based on a September 19, 2010 stabbing of a roommate; a jury convicted him of elevated aggravated assault.
He was sentenced to 22 years, with all but 20 years suspended, plus probation; the conviction was affirmed on direct appeal.
Manley filed a post-conviction relief petition alleging ineffective assistance of trial counsel; at hearing he pressed three grounds but on appeal pursued only the claim that counsel failed to obtain and present the victim’s medical records documenting a history of self-harm.
Trial counsel had investigated, retained a private investigator, and pursued a defense theory that the victim inflicted his own wounds; counsel elicited testimony at trial that the victim had a history of self-injury and had told hospital staff he might have harmed himself.
The victim’s medical records (not subpoenaed at trial) showed multiple prior incidents of actual or threatened self-injury, including prior stabbings, which the post-conviction court found would have supported the self-harm theory but would not overcome other evidence (wound locations and nature) undermining a self-infliction explanation.
The post-conviction court concluded counsel provided "reasonably effective assistance" and denied relief; the Maine Supreme Judicial Court affirmed, applying Strickland’s deferential standard and presumption that counsel’s choices can constitute reasonable trial strategy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for not subpoenaing the victim’s medical records documenting past self-harm	Manley: failure to obtain records deprived him of evidence bolstering the self-infliction defense and thus constituted ineffective assistance	State: counsel made a reasonable strategic choice to rely on discovery and live testimony; counsel had investigated and elicited key self-harm admissions at trial	Court: Counsel provided "reasonably effective assistance"; decision to forego records was a reasonable tactical choice and did not establish ineffective assistance

Strickland v. Washington, 466 U.S. 668 (establishes two‑part ineffective-assistance test and "reasonably effective assistance" standard)
Roberts v. State, 103 A.3d 1031 (Me. 2014) (applied deferential review to strategic choices of counsel under Strickland)
Duncan v. Robbins, 193 A.2d 362 (Me. 1963) (federal constitutional interpretations by the U.S. Supreme Court are binding on Maine courts)