Travis Steed v. State of Tennessee
W2017-00156-CCA-R3-PC
| Tenn. Crim. App. | Dec 19, 2017Background
- On Feb. 26, 2012 a shooting at the Karma Lounge in Jackson left one person dead and multiple wounded; Travis Steed was indicted and later convicted of multiple offenses including felony murder and attempted murder.
- Steed was convicted after a jury trial and received an effective life sentence plus 24 years.
- Steed filed a pro se petition for post-conviction relief; counsel was appointed but did not amend the petition.
- At the post-conviction hearing Steed alleged only ineffective assistance of trial counsel for failing to interview and call certain witnesses critical to his defense.
- Trial counsel testified he reviewed discovery, visited Steed multiple times, pursued impeachment of key prosecution witnesses, attempted to locate two potential defense witnesses (unsuccessfully), and deliberately did not interview numerous witnesses listed on the indictment because he deemed them unlikely to help.
- The post-conviction court credited trial counsel’s testimony, found counsel’s performance within professional norms, found no prejudice under Strickland, and denied relief; this Court affirmed.
Issues
| Issue | Petitioner’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for failing to interview or call unidentified witnesses | Counsel failed to investigate and call witnesses critical to defense, prejudicing outcome | Counsel’s investigation and strategy were reasonable; petitioner failed to identify or present the missing witnesses or their testimony | Denied — petitioner failed to prove deficient performance or prejudice; no material witnesses were produced at the post-conviction hearing |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two-part ineffective assistance test)
- Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (competence standard and deference to tactical decisions)
- Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (prejudice and deficiency framework under Strickland)
- Black v. State, 794 S.W.2d 752 (Tenn. Crim. App. 1990) (requirement that claimed omitted witnesses testify at post-conviction hearing to prove prejudice)