Moore v. Beard, 2014 U.S. Dist. LEXIS 118694

Moore was retried in 1983 and convicted of first degree murder, conspiracy, robbery, theft, and recklessly endangering another person.
The Third Circuit remanded after 2012 to conduct an evidentiary hearing on ineffective assistance claims and Brady issues.
At the 2014 evidentiary hearing, the court found trial counsel deficient for failing to present Jones and for failing to impeach Scott.
The court treated the Strickland two‑prong test and applied AEDPA standards in evaluating deficiencies and prejudice.
The court vacated Moore’s convictions and granted a writ of habeas corpus directing retrial within 90 days or release; stay and related procedural rulings followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
whether counsel’s failure to present Jones as a defense witness was ineffective	Moore	Moore’s counsel deemed Jones unhelpful/not a strategic choice	Yes; failure was deficient and prejudicial.
whether counsel’s failure to impeach Ricardo Scott was ineffective	Moore	Cross-examination of Scott did not adequately exploit his plea deal and bias	Yes; failure was deficient and prejudicial.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part standard for ineffective assistance of counsel)
Burt v. Titlow, 134 S. Ct. 10 (U.S. 2013) (strict deference framework and application to counsel decisions)
Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (AEDPA deference and reasonableness review of state court decisions)
Harrington v. Richter, 562 U.S. 86 (U.S. 2011) (clarifies prejudice inquiry and standard of review under Strickland)
Grant v. Lockett, 709 F.3d 224 (3d Cir. 2013) (impeachment evidence and defense strategy; bias of informants)
Jacobs v. Horn, 395 F.3d 92 (3d Cir. 2005) (totality of evidence in prejudice evaluation; dependency on record)