Jenkins v. State, 2011 WY 141

Jenkins was charged with misdemeanor animal cruelty for a horse in dire condition.
Trial and district courts convicted him; Wyoming Supreme Court granted petition for review.
Petitioner claimed ineffective assistance of counsel on three trial-level theories.
Key testimony involved arrest/incarceration details and questions about credibility of other witnesses.
Court applied Strickland two-prong test and reviewed de novo for prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did trial counsel err by not objecting to arrest/incarceration testimony?	Jenkins claims prejudice from arrest/incarceration references.	References provided context; no material prejudice.	No material prejudice; no ineffective assistance.
Did trial counsel err by not objecting to improper witness-comment on another witness's testimony?	Prosecutor misconduct prejudiced the defense.	Misconduct but not prejudicial under factors.	No material prejudice; no reversal.
Did trial counsel err by not objecting to questions about irrelevant evidence?	Irrelevant evidence admitted to prejudice trial.	Any prejudice was not material; evidence limited.	No material prejudice; affirmed.

Hirsch v. State, 135 P.3d 593 (Wy. 2006) (ineffective assistance requires deficient performance and prejudice; de novo review)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance)
Dettloff v. State, 152 P.3d 376 (Wyo. 2007) (ineffectiveness review requires prejudice show)
Martinez v. State, 128 P.3d 652 (Wyo. 2006) (burden on appellant; prejudice must be shown)
Pendleton v. State, 180 P.3d 212 (Wyo. 2008) (prejudice defined; reasonable probability standard)
Beaugureau v. State, 56 P.3d 626 (Wyo. 2002) (improper lying/mistaken questions; jury assessment disfavored)
Foster v. State, 224 P.3d 1 (Wyo. 2010) (jail-related testimony rarely prejudices when context present)
Janpol v. State, 178 P.3d 396 (Wyo. 2008) (curative instructions and jury credibility considerations)