State v. Wilson, 1 CA-CR 15-0148-PRPC

Wilson was convicted of first‑degree murder, first‑degree burglary, armed robbery, theft, possession of marijuana for sale, possession or use of narcotic drugs, and solicitation to hinder prosecution in the first degree; sentenced to natural life plus 2.5 years; direct appeal affirmed the convictions and sentences.
He filed a petition for post‑conviction relief alleging ineffective assistance of trial counsel.
The superior court held an evidentiary hearing and denied relief after finding colorable claims and evaluating the record.
The court reviewed the post‑conviction ruling for abuse of discretion and the factual findings for clear error.
The petition for post‑conviction relief was reviewed on its merits, and the appellate court granted review but denied relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for suppression‑motion omission	Wilson asserts counsel failed to move to suppress warrant‑seized evidence.	State contends counsel acted within objective trial strategy given timing and entry facts.	Denied relief.
Inconsistent defense theories	Wilson argues counsel advanced conflicting defenses (heroin ring vs others).	State contends defense theory was coherent and aimed at challenging police investigation.	Denied relief.
Failure to admit statements as Rule 613 prior inconsistent statements	Wilson claims counsel should have admitted the heroin ring statements as Rule 613 prior inconsistent statements.	State argues statements were properly excluded as hearsay and not fit for 613 treatment.	Denied relief.
Right to effective cross‑examination during PCR hearing	Wilson contends he was denied effective cross‑examination of trial counsel.	State argues issue was outside petition scope and not raised as a viable ineffectiveness claim.	Denied relief.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance and prejudice)
State v. Schrock, 149 Ariz. 433 (Ariz. 1986) (abuse of discretion standard in reviewing PCR rulings)
State v. Berryman, 178 Ariz. 617 (App. 1994) (review of post‑conviction findings on appeal)
State v. Valdez, 160 Ariz. 9 (Ariz. 1989) (procedural framework for ineffective assistance claims)
Krone v. Hotham, 181 Ariz. 364 (Ariz. 1995) (limits on curing tactical decisions as ineffective assistance)