Marquis D. Hendricks v. State of Tennessee, E2016-02123-CCA-R3-PC

Marquis D. Hendricks was convicted by a Knox County jury of first-degree murder, attempted first-degree murder, and drug offenses; he received an effective life sentence.
The convictions arose from a November 2012 incident in which Hendricks sold crack cocaine to Nathaniel Bolding and Keith Hammock; Hammock was fatally shot and Bolding wounded as they drove away.
At trial Hendricks argued self-defense; the jury was instructed on self-defense and convicted him. On direct appeal convictions were affirmed.
Hendricks sought post-conviction relief claiming trial counsel was ineffective for failing to request jury instructions on the statutory defenses of duress and necessity.
At the post-conviction evidentiary hearing trial counsel testified he pursued a self-defense strategy based on Hendricks’ account and did not believe duress/necessity fit the facts; the court found counsel experienced and the strategy reasonable and denied relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for not requesting a duress instruction	Hendricks: counsel should have requested duress instruction	State: facts did not support duress; counsel reasonably pursued self-defense	Denied — duress inapplicable (especially to homicide) and counsel's choice reasonable
Whether counsel was ineffective for not requesting a necessity instruction	Hendricks: counsel should have requested necessity instruction	State: necessity inapplicable; situation was human-caused and counsel reasonably chose self-defense	Denied — necessity not supported and counsel's strategy reasonable
Whether counsel's performance fell below objective professional standards	Hendricks: omission was deficient performance	State: counsel thoroughly prepared, investigated, and chose a sound trial tactic	Denied — court found no deficient performance
Whether any deficient performance prejudiced the defense	Hendricks: omission likely changed result	State: no reasonable probability outcome would differ; defenses not properly raised by facts	Denied — no prejudice shown

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective-assistance test)
Goad v. State, 938 S.W.2d 363 (Tenn. Crim. App.) (counsel performance standard; prejudice requirement)
Henley v. State, 960 S.W.2d 572 (Tenn.) (review of counsel effectiveness and deference to trial strategy)
United States v. Bailey, 444 U.S. 394 (discusses distinction between duress and necessity)
State v. Culp, 900 S.W.2d 707 (Tenn. Crim. App.) (statutory general-defenses framework and burden to fairly raise them)