Khaleefa Lambert v. State of Tennessee
M2016-01059-CCA-R3-PC
Tenn. Crim. App.Mar 2, 2017Background
- Petitioner Khaleefa Lambert was convicted by a Montgomery County jury of first-degree (premeditated) murder and especially aggravated kidnapping for the 2009 killing of his wife; sentences of life plus 18 years were imposed and affirmed on direct appeal.
- Facts at trial: Lambert confronted the victim at a motel, removed her to an SUV, and she suffered multiple stab wounds (including a fatal neck wound) and died; Lambert made post-incident calls saying he “hurt her,” was emotional, and claimed he saw her with another man.
- Evidence included motel employee and witness testimony, Lambert’s recorded statements and 9-1-1/family calls, forensic pathology establishing a rapid fatal wound, and serology/DNA linking recent intercourse to Lambert.
- Post-conviction petition alleged ineffective assistance of lead trial counsel for (1) failing to investigate/research evidence and case law undermining the State’s premeditation theory, (2) failing to discuss jury selection, and (3) failing to properly consult about Lambert’s decision to testify.
- At the post-conviction hearing, Lambert testified about missed investigative steps (e.g., phone records, earlier interview of Lieutenant Garth), asserted counsel pressured him not to testify, and said suppression motions were not pursued; lead counsel testified he met Lambert frequently, investigated, researched premeditation law, and advised against testimony as tactically unsound.
- The post-conviction court credited counsel, found no deficient performance, denied relief, and this Court affirmed, concluding Lambert failed to prove deficient performance or resulting prejudice (and waived two claims not raised below).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel rendered ineffective assistance by failing to investigate/research to support a heat-of-passion/undermine premeditation defense | Lambert: counsel failed to timely interview Lieutenant Garth, did not obtain phone records or relevant case law, and failed to object to certain prosecutor arguments, which undermined a heat-of-passion theory | State/Counsel: counsel investigated, researched premeditation law, used calls to show state of mind, and strategic choices (including not objecting) were reasonable trial tactics | Denied — court found no proven deficiency; petitioner failed to identify what evidence would have negated trial motive and court credited counsel’s testimony |
| Whether counsel failed to discuss jury selection with petitioner | Lambert: counsel did not adequately discuss voir dire or seek change of venue despite media attention | State: claim waived (not raised in petition) and counsel testified voir dire covered media exposure and venue motion would likely fail | Waived — not raised below, so not considered on appeal |
| Whether counsel failed to properly advise/discuss decision to testify | Lambert: he wanted to testify; counsel discouraged him and used family to dissuade him, affecting his choice | State/Counsel: counsel prepared clients who wished to testify, advised against testifying for strategic reasons, and denial of testimony was a tactical decision | Waived — claim not raised in post-conviction petition and thus not considered on appeal |
| Whether petitioner suffered prejudice from alleged counsel deficiencies | Lambert: suppression of statements or additional investigation would have supported voluntary manslaughter verdict | State: even absent challenged conduct, no reasonable probability of different outcome given strength of evidence | Denied — court did not reach prejudice in detail after finding no deficient performance; confidence in outcome not undermined |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part standard for ineffective assistance: deficient performance and prejudice)
- Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (counsel effective if within range of competence; review limits)
- Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (application of Strickland in Tennessee; prejudice standard)
- Finch v. State, 226 S.W.3d 307 (Tenn. 2007) (no need to analyze both Strickland prongs if one fails)