Keelon Jenkins v. Michael Evans, 663 F. App'x 553

Jenkins was convicted of first-degree murder after a jury trial; defense argued he believed a robbery was staged and thus lacked felony-murder culpability.
Central factual dispute at trial: who masterminded the staged robbery—Jenkins testified Frank Valentine did; defense counsel told the jury Anthony Young was responsible.
Counsel repeatedly contradicted Jenkins in opening and closing statements, calling into question Jenkins’s credibility in front of the jury.
Counsel promised evidence tying Young to the plot but never presented that evidence at trial.
The prosecutor emphasized the split between Jenkins and his lawyer, making credibility the central theme of closing argument; jury convicted after three days of deliberation.
Jenkins sought habeas relief in state court; the California Supreme Court summarily denied relief; on federal habeas review the Ninth Circuit affirmed under AEDPA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel rendered constitutionally ineffective assistance by attacking client’s credibility at trial	Jenkins: counsel undermined his testimony by repeatedly telling jury his client was lying and advancing an unproven alternate theory, constituting deficient performance and prejudicing outcome	State: counsel’s conduct could be a strategic choice and similar narrative criticisms have not been held deficient; under AEDPA courts must defer to state-court denial	Court: Affirmed — state court’s summary denial was not an unreasonable application of Strickland; even assuming counsel undercut credibility, the state court reasonably could find no deficient performance or no Strickland prejudice

Strickland v. Washington, 466 U.S. 668 (1984) (two-part ineffective-assistance test: deficiency and prejudice)
Harrington v. Richter, 562 U.S. 86 (2011) (federal courts must defer to state-court determinations under AEDPA; review asks whether state court unreasonably applied Strickland)
Yarborough v. Gentry, 540 U.S. 1 (2003) (illustrates that counsel’s harsh credibility attacks on client are not per se ineffective)
Knowles v. Mirzayance, 556 U.S. 111 (2009) (reinforces the ‘‘doubly deferential’’ standard when evaluating Strickland claims on habeas)