Robert Stanford, III v. Charles Ryan, 692 F. App'x 339

Background

In 2008 Robert Stanford was convicted by an Arizona jury of second-degree murder; he admitted shooting the victim but claimed self-defense and was sentenced to 18 years.
Stanford pursued direct and state post-conviction appeals unsuccessfully, then filed a federal habeas petition under 28 U.S.C. § 2254 claiming ineffective assistance of trial counsel (Strickland).
The ineffective-assistance claim focused on counsel’s alleged failure to interview or call eyewitness Sheikh Ajamu, who later (four years after the shooting) executed an affidavit supporting Stanford’s self-defense story.
Trial counsel had communicated with Ajamu on several occasions and decided not to call him, believing Ajamu’s account conflicted with Stanford’s evolving versions and could harm the defense.
The Arizona Court of Appeals and the federal district court found counsel’s decision was a reasonable tactical choice; the Ninth Circuit reviewed de novo under AEDPA and applied the doubly deferential Strickland/AEDPA standard.
The court also held that even if counsel’s performance were deficient, Ajamu’s testimony likely would have been contradicted by strong physical evidence presented by the prosecution, so Stanford could not show prejudice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was constitutionally ineffective for failing to interview/call eyewitness Ajamu	Counsel failed to investigate/call Ajamu whose testimony would have corroborated Stanford’s self-defense claim	Counsel reasonably investigated and made a tactical decision not to call Ajamu because his account conflicted with Stanford’s and could harm the defense	Court held counsel’s decision was reasonable; performance not shown to be deficient under Strickland/AEDPA
Whether counsel’s alleged deficiency prejudiced Stanford (Strickland prejudice prong)	Had Ajamu testified, it was reasonably likely the outcome would differ because his testimony supported self-defense	Physical evidence would have refuted Ajamu’s claimed testimony; therefore no reasonable likelihood of a different outcome	Court held Stanford failed to show prejudice; verdict likely would stand despite Ajamu’s testimony
Standard of review under AEDPA for state-court adjudication of Strickland claims	State court unreasonably applied Strickland and AEDPA standards	Federal courts must apply doubly deferential review; state court decision must be unreasonable to grant relief	Court applied AEDPA/Strickland framework and found state court’s decision was not unreasonable
Duty to investigate vs tactical choice	Trial counsel had a duty to pursue favorable eyewitness testimony	Attorneys need not pursue investigations that are likely fruitless or harmful; decision judged from counsel’s perspective at the time	Court held counsel’s choice fell within reasonable tactical judgment; no ineffective assistance

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (constitutional standard for ineffective assistance of counsel)
Harrington v. Richter, 562 U.S. 86 (attorney need not pursue investigation that would be fruitless or harmful)
Yarborough v. Gentry, 540 U.S. 1 (describing double deference when applying Strickland under AEDPA)
Woods v. Sinclair, 764 F.3d 1109 (AEDPA review of last reasoned state court decision)
Brodit v. Cambra, 350 F.3d 985 (standard for de novo review of habeas denial)
Murray v. Schriro, 746 F.3d 418 (explaining reasonable argument that counsel satisfied Strickland under AEDPA)
Eggleston v. United States, 798 F.2d 374 (consider strength of government’s case when assessing duty to investigate)