Strickland v. Goguen, 3 F.4th 45

Eleven-year-old Haleigh Poutre was hospitalized Sept. 11, 2005 with severe traumatic brain injury and evidence of long‑term abuse; police found bruises, burns, blood, and weapons in the home.
Eyewitnesses (Holli’s daughter J and neighbor Weiss) testified to repeated physical abuse by Holli and incidents in which Strickland was present and participated (stair‑kicking, strikes with a bat and a tubular wand, dragging, striking with a hand).
Strickland was indicted on multiple counts including assault and battery causing substantial injury under Mass. Gen. Laws ch. 265 § 13J(b) (either direct assault or wantonly/recklessly permitting another to assault), dangerous‑weapon assaults, and general assault.
Defense theory: Strickland claimed ignorance — Holli had Munchausen Syndrome by Proxy (MSBP) and had deceived medical providers into thinking Haleigh self‑injured; defense sought to introduce medical providers’ testimony/records and MSBP expert evidence, which the trial judge largely excluded as irrelevant/hearsay.
Jury convicted on five counts (reckless/wanton permitting on counts 1–2; direct abuse on counts 3, 5, 6); MAC affirmed the convictions, holding any exclusion was harmless and counsel not ineffective; SJC denied review; district court denied habeas under AEDPA; First Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of medical providers' testimony/records — right to present a defense and harmless error	Exclusion prevented jury from seeing central corroboration that Holli deceived providers; evidence was the crux of Strickland's defense about what he knew	Excluded evidence was marginal/cumulative (Krzyzek and other testimony already informed jury of self‑injury reports); Strickland had direct observations and strong eyewitness/physical evidence; any error harmless beyond reasonable doubt	Affirmed. MAC reasonably applied Chapman harmlessness test; exclusion, if error, was harmless under AEDPA deference
Ineffective assistance for failing to consult/call MSBP expert	Trial counsel failed to investigate/hire an expert who would explain MSBP and why a father could be legitimately unaware, depriving Strickland of corroboration and effective defense	Counsel considered MSBP and reasonably declined as experts’ reports focused on providers (not on whether Holli deceived Strickland); expert testimony unlikely to overcome eyewitness and physical evidence; strategic decision reasonable	Affirmed. MAC reasonably applied Strickland; counsel’s performance not constitutionally deficient given record and AEDPA’s doubly deferential review

Strickland v. Washington, 466 U.S. 668 (1984) (establishes two‑prong ineffective‑assistance test)
Chapman v. California, 386 U.S. 18 (1967) (constitutional error reversible only if not harmless beyond a reasonable doubt)
Harrington v. Richter, 562 U.S. 86 (2011) (explains AEDPA deference and difficulty of showing unreasonable application of Strickland)
Williams v. Taylor, 529 U.S. 362 (2000) (defines "unreasonable application" standard under AEDPA)
Davis v. Ayala, 576 U.S. 257 (2015) (discusses AEDPA limits on habeas relief and harmlessness principles)
Dorsica v. Marchilli, 941 F.3d 12 (1st Cir. 2019) (treats state‑court factual findings as presumptively correct on habeas)
Commonwealth v. Saferian, 315 N.E.2d 878 (Mass. 1974) (Massachusetts test at least as protective as federal standard for presenting a defense)