Logan v. State
293 P.3d 969
Okla. Crim. App.2013Background
- Logan convicted by jury of Robbery with a Firearm and First-Degree Robbery; sentences life and 40 years consecutive.
- Direct appeal previously affirmed; Logan later filed a non-capital post-conviction relief application in district court.
- District Court denied Logan's post-conviction relief in 2011 without addressing merits of appellate-counsel claims.
- Logan asserted six propositions, including ineffective assistance of trial and appellate counsel; claims were largely deemed waived or non-meritorious apart from appellate counsel.
- Oklahoma Post-Conviction Procedure Act governs non-capital post-conviction proceedings; the district court’s order was found deficient for failing to conduct proper Strickland analysis and failings in findings.
- This Court vacated the district court’s order and remanded for (a) an evidentiary hearing if genuine issues of material fact exist regarding appellate-counsel ineffectiveness, or (b) specific, merits-based findings addressing each asserted claim if no such hearing is needed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly analyzed appellate-counsel ineffectiveness under Strickland. | Logan allege appellate-counsel ineffectiveness. | District court applied Strickland and examined merits; concedes viability but found no prejudice. | Remanded to evaluate merits and, if warranted, hold evidentiary hearing. |
| Whether the district court failed to make required findings of fact and law. | Order insufficiently detailed; failed to conclude on each claim. | State briefed, district court merely stated conclusory findings. | Remand for explicit findings on each issue. |
| Whether there are genuine issues of material fact requiring an evidentiary hearing. | There may be disputed facts about arrest/search and waiver of rights. | Record presented suggests no clear material factual disputes. | Remand to determine if an evidentiary hearing is necessary. |
| Whether waived or procedurally barred claims should be revisited in post-conviction. | Some claims not raised on direct appeal could be revisited because of ineffective-assistance claim. | WAivers and waivers apply; review limited. | The court acknowledges procedural context but remands to address proper analysis. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong standard for ineffective assistance of counsel)
- Smith v. Robbins, 528 U.S. 259 (2000) (requires showing deficient performance and prejudice; strong presumption of competence)
- Coddington v. State, 259 P.3d 833 (Okla. Crim. App. 2011) (post-conviction framework; standard for ineffective appellate counsel)
- Neill v. Gibson, 278 F.3d 1044 (10th Cir. 2001) (dead-bang winner concept; warranted analysis of omitted issues)
- Robbins v. United States, 528 U.S. 259 (2000) (discusses strategy of selecting issues on appeal; standard for prejudice)