Mattox v. State
267 P.3d 746
Kan.2011Background
- Mattox was convicted of aiding and abetting second-degree murder after giving his gun to Gigger, who shot Lane following Mattox’s statement that Lane deserved to be shot.
- On habeas review, Mattox claimed appellate counsel’s inadequacy would have changed the outcome of his appeal.
- The appellate record focused on whether Mattox reinvoked Miranda rights during custodial interrogation and whether such statements and the gun evidence should have been excluded.
- The district court suppressed some statements but allowed a handwritten statement; the gun and ballistics evidence remained in dispute under Miranda and Patane principles.
- Even without the challenged statements, substantial evidence supported both murder and gun-discharge convictions; the State’s theory did not require the excluded evidence to convict.
- The court reversed the district court’s habeas relief, holding no reasonable possibility of a different appellate result had the contested evidence been excluded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did appellate counsel’s conduct prejudice Mattox on appeal? | Mattox | Mattox | No prejudice; one would not have changed the outcome. |
| Would exclusion of statements and gun evidence alter the verdict? | Mattox | Mattox | No; overwhelming evidence supported the convictions regardless. |
| Does Patane permit admission of physical evidence obtained from custodial statements made without Miranda warnings? | State | Mattox | Yes, Patane supports admission of gun/ballistics evidence despite possible Miranda issues. |
| What standards govern appellate ineffectiveness claims and prejudice in this context? | Mattox | State | Strickland prejudice requires showing a reasonable probability of success on appeal; here none. |
Key Cases Cited
- United States v. Patane, 542 U.S. 630 (U.S. 2004) (physical evidence may be admitted when obtained from voluntary statements despite Miranda issues)
- State v. Schultz, 289 Kan. 334 (Kan. 2009) (patane-like treatment of physical evidence; custodial interrogation and suppression matters)
- Baker v. State, 243 Kan. 1 (Kan. 1988) (standard for appellate prejudice in ineffective-assistance claims)
- State v. Ward, 256 P.3d 801 (Kan. 2011) (harmless-error considerations in Miranda-related disclosures)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (test for ineffective assistance: deficient performance and prejudice)
- Kargus v. State, 284 Kan. 908 (Kan. 2007) (prejudice prong in ineffective-assistance claims)