Stephen J. R. v. Commissioner of Correction, 178 Conn. App. 1

Petitioner Stephen J. R. was convicted of multiple counts of sexual assault of a child; the Supreme Court affirmed his conviction on direct appeal in State v. Stephen J. R.
Allegations involved repeated incidents between 2002–2003; forensic interview (2008) and delayed disclosure were central to the prosecution’s case.
Petitioner filed a second amended habeas petition alleging trial counsel was ineffective for not consulting or calling an expert on false memory / suggestibility in child sexual-abuse interviews.
At the habeas trial, defense expert Dr. David Mantell testified that repeated questioning and certain interview techniques can produce false memories; he opined the victim’s interview had some problematic features.
Trial counsel Christopher Eddy testified he researched interviewing protocols and literature, considered false memory but strategically elected to attack the child’s credibility rather than present expert testimony.
The habeas court found counsel’s performance reasonable and denied the writ and certification to appeal; the appellate court dismissed the appeal for lack of a debatable issue.

Issue	Petitioner’s Argument	Respondent’s Argument	Held
Whether trial counsel was ineffective for not consulting/calling a false‑memory expert	Eddy’s failure deprived Stephen of competent representation; an expert could have shown suggestive interviewing and false memory, likely changing the outcome	Eddy conducted research, considered the defense, and reasonably chose a credibility strategy; calling an expert was not required and would not likely have produced a different result	Denied — counsel’s choice was a reasonable, strategic decision after investigation; petitioner failed to show deficient performance or prejudice

Strickland v. Washington, 466 U.S. 668 (1984) (establishes the two‑prong test for ineffective assistance of counsel)
State v. Stephen J. R., 309 Conn. 586 (2013) (direct‑appeal decision describing the underlying facts and affirming conviction)
Michael T. v. Commissioner of Correction, 307 Conn. 84 (2012) (no bright‑line rule requiring defense expert in every sexual‑assault case; experts may be required in certain circumstances)
Skakel v. Commissioner of Correction, 325 Conn. 426 (2016) (strategic choices made after thorough investigation are virtually unchallengeable)
Brian S. v. Commissioner of Correction, 172 Conn. App. 535 (2017) (discusses reasonableness of counsel’s investigation and strategic limitations)