Madigosky v. Commissioner of Correction, 158 A.3d 809

Petitioner Madigosky was convicted of murder and later filed a habeas petition claiming ineffective assistance of trial counsel for failing to adequately prepare an expert witness.
Zelman, the petitioner’s psychiatrist, testified at trial about mental illness; evidence showed pre- and post-discharge psychiatric treatment and nonadherence to medications.
Defense at trial raised two insanity theories: cognitive and volitional; Zelman testified the petitioner was psychotic but did not clearly delineate which theory applied.
Habeas court denied relief, concluding no reasonable probability that more thorough preparation would have changed the outcome.
Appellate court affirmed, holding that prejudice prong of Strickland was not satisfied and thus no merit to the claim of ineffective assistance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to adequately prepare Zelman violated Strickland	Crozier’s lack of preparation prevented Zelman from distinguishing cognitive vs. volitional insanity.	Zelman’s testimony, already largely duplicative, could not show a probability of different trial result.	Prejudice not shown; no ineffective assistance

State v. Madigosky, 291 Conn. 28 (Conn. 2009) (insanity standards and appellate review context)
Strickland v. Washington, 466 U.S. 668 (Supreme Court 1984) (two-prong test: performance and prejudice)
Nieves v. Commissioner of Correction, 51 Conn. App. 615 (Conn. App. 1999) (prejudice prong may resolve appeal without addressing performance)
Martin v. Commissioner of Correction, 155 Conn. App. 223 (Conn. App. 2015) (no prejudice where expert testimony would not have changed outcome)
Taft v. Commissioner of Correction, 159 Conn. App. 537 (Conn. App. 2015) (prejudice analysis governs ineffectiveness claim)
Browne v. Commissioner of Correction, 158 Conn. App. 1 (Conn. App. 2015) (Strickland standard applied by Connecticut appellate courts)