State of New Jersey v. Antoine J. Martin, A-0331-23

Antoine J. Martin was convicted by a jury of robbery, burglary, false imprisonment, theft by extortion, and hindering, based on his role in a home invasion and robbery with two co-defendants.
On direct appeal, Martin’s conviction was affirmed and his case remanded for resentencing; after resentencing, he filed a petition for post-conviction relief (PCR).
Martin's PCR argued ineffective assistance of counsel on the basis of his attorney’s alleged conflict of interest and failure to call exculpatory witnesses (notably, his co-defendant Hoffman).
The trial court denied the PCR without an evidentiary hearing, finding no actionable conflict of interest and no prejudice from the failure to call additional witnesses.
On appeal, Martin claimed the PCR court erred by denying his ineffectiveness claims and conflict of interest claims without more probing factual review.
The Appellate Division reviewed the PCR denial de novo, focusing on whether counsel’s performance was deficient and prejudicial under the Strickland standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance: Failure to call witness	Counsel’s strategy was reasonable, no prejudice.	Hoffman’s testimony could exculpate Martin; should be treated as credible	No prejudice shown; testimony insufficient to alter verdict
Conflict of interest (dual representation)	No true conflict; dual matters were remote and unrelated.	Conflict existed due to representation of witness's grandson	No conflict; dual representation was remote/unrelated
Appellate counsel ineffectiveness	Not required to raise every possible issue on appeal.	Counsel erred by omitting certain claims (e.g., conflict of interest).	No error; appellate counsel's choices were reasonable
Need for evidentiary hearing on PCR	No evidentiary hearing required absent prima facie showing	PCR court should have assessed witness credibility through a hearing	No prima facie case; hearing was properly denied

Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong test for ineffective assistance of counsel)
Jones v. Barnes, 463 U.S. 745 (1983) (appellate counsel is not obligated to raise every nonfrivolous issue on appeal)
Miranda v. Arizona, 384 U.S. 436 (1966) (addresses suspect’s right to remain silent and to counsel during custodial interrogation)
State v. Harris, 181 N.J. 391 (2004) (PCR court's legal conclusions are reviewed de novo)
State v. O’Neil, 219 N.J. 598 (2014) (clarifies prejudice requirement under Strickland)