Jody A. Miller v. State
Background
- Petitioner Jody A. Miller entered an Alford plea to second-degree murder and later filed a petition for post-conviction relief asserting multiple ineffective-assistance claims.
- The State moved for summary dismissal; the district court granted the motion without an evidentiary hearing.
- On appeal the State conceded Miller did not waive post-conviction rights by entering an Alford plea; the court therefore did not decide waiver.
- Miller alleged trial counsel was ineffective for (1) failing to move to suppress his confession (claims of intoxication, coercion, Miranda violations), (2) failing to investigate/obtain DNA, blood-spatter evidence, and expert witnesses, and (3) failing to inform Miller of specific trial strategies; he also asserted cumulative error.
- The district court dismissed all claims for lack of admissible supporting evidence showing a prima facie case; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller waived post-conviction relief by pleading Alford | Miller: did not waive post-conviction rights by Alford plea | State: originally argued waiver; later conceded on appeal | State conceded; court declined to decide waiver further |
| Whether counsel was ineffective for not moving to suppress confession | Miller: confession involuntary due to intoxication, coercion, Miranda violations | State: Miller produced no evidence intoxication or police coercion occurred; motion likely would fail | No prima facie showing; claim summarily dismissed |
| Whether counsel failed to investigate (DNA, blood-spatter, experts) | Miller: counsel should have obtained/used physical evidence and experts to show someone else stabbed the victim | State: Miller offered only speculative/conclusory allegations and no evidence those investigations would change outcome | No admissible evidence that further investigation would have altered result; claim summarily dismissed |
| Whether counsel failed to inform Miller of trial strategies / cumulative error | Miller: counsel did not inform him of specific strategies; cumulative errors denied him fair trial | State: Miller provided no specifics, evidence, or authority showing prejudice | Conclusory and unsupported; individual claims unfounded so cumulative-error doctrine inapplicable |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance: deficient performance and prejudice)
- Aragon v. State, 114 Idaho 758 (1988) (objective-reasonableness standard for attorney performance)
- Lint v. State, 145 Idaho 472 (2008) (failure to file motion: probability of success on the motion pertinent to ineffective-assistance analysis)
- Roman v. State, 125 Idaho 644 (1994) (petitioner's conclusory allegations without admissible evidence insufficient to avoid summary dismissal)
- Wolf v. State, 152 Idaho 64 (2011) (post-conviction petitioner must present admissible evidence supporting allegations)
- Charboneau v. State, 140 Idaho 789 (2004) (if petitioner alleges facts that, if true, would entitle relief, an evidentiary hearing is required)