Stanley Abernathy James v. State of Tennessee
E2016-01909-CCA-R3-PC
| Tenn. Crim. App. | Jul 26, 2017Background
- Petitioner Stanley Abernathy James, convicted by a Knox County jury of second‑degree murder for the August 4, 2009 shooting of Henry James, sentenced to 25 years; direct appeal affirmed and supreme court denied review.
- At trial, prosecution witnesses placed Petitioner at the scene after a knock at the screen door, described a dispute and two gunshots; a .40 caliber handgun with serial number ground off was found elsewhere and ballistics linked the scene casing and bullet to that gun.
- Petitioner testified he went to buy marijuana, saw the victim reach for a gun through the screen door, fired twice in perceived self‑defense, and fled; DNA on the gun was inconclusive but partially consistent with Petitioner.
- Post‑conviction petition alleged ineffective assistance of trial counsel based on: (1) failing to pursue voluntary manslaughter instead of self‑defense; (2) requesting an improper self‑defense jury instruction; (3) failing to secure/witness testimony (Miranda Davidson); and (4) failing to obtain Petitioner’s medical records/evaluation.
- At the post‑conviction evidentiary hearing, investigator and defense investigator testimony showed attempts to locate witnesses; Petitioner testified about his head‑injury history and expectations about counsel’s strategy; post‑conviction court found counsel effective and denied relief.
Issues
| Issue | James's Argument | State's Argument | Held |
|---|---|---|---|
| Whether counsel was deficient for not pursuing voluntary manslaughter instead of self‑defense | Trial counsel switched to self‑defense mid‑trial against James’s wishes; manslaughter would better fit facts | Counsel reasonably selected self‑defense as a viable strategy; no deficient performance shown | No deficiency; counsel’s strategy was reasonable and no relief granted |
| Whether counsel erred by requesting an improper self‑defense jury instruction | Counsel sought to omit the unlawful‑activity duty‑to‑retreat language, which James says was error | Trial court rejected the request and gave correct instruction; any request did not prejudice James | No prejudice shown; request denied at trial and would have favored acquittal if granted |
| Whether counsel was ineffective for failing to call Miranda Davidson | Davidson would have testified Petitioner sought to buy marijuana and was at girlfriend’s apt.; her testimony would explain presence | Investigator and defense investigator tried to contact her; her testimony would corroborate illegal activity and not undercut conviction | No prejudice; her testimony would only confirm illegal activity and not undermine verdict |
| Whether counsel was ineffective for failing to obtain medical records/exam | James alleged prior head‑shot, PTSD/Bipolar, blackouts; records/exam could have supported defense/strategy | No proof offered at hearing what records/exam would have shown or how result would differ | No prejudice proven; speculative without records, so no relief |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong ineffective‑assistance test: deficient performance and prejudice)
- Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (counsel effective if within range of competence; deference to trial strategy)
- Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (prejudice standard and evaluation of counsel performance)
- Finch v. State, 226 S.W.3d 307 (Tenn. 2007) (no need to address both Strickland prongs if one not met)