Woodson v. State
2012 Ind. App. LEXIS 70
| Ind. Ct. App. | 2012Background
- Keith Woodson was convicted of murder and Class A misdemeanor carrying a handgun without a license after a second trial; the first trial ended in mistrial and defense had presented alibi witnesses.
- During Owens's and Johnson's eyewitness identifications, questions arose about how the identifications were obtained and potential reliability, including prior rumors that Woodson was
- the nickname
- PG.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel at second trial | Woodson | Harper acted within reasonable professional judgment | Not ineffective; cross-examination adequate; no prejudice |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong standard: deficiency and prejudice)
- Beauchamp v. State, 788 N.E.2d 881 (Ind.Ct.App. 2003) (public funds for an expert may be available to indigent defendants)
- Farris v. State, 818 N.E.2d 63 (Ind.Ct.App. 2004) (eyewitness identification expert testimony generally inadmissible under Rule 704/702 in certain two-witness cases; admissibility case-by-case)
- Sweeney v. State, 886 N.E.2d 1 (Ind.Ct.App.2008) (counsel not ineffective for failing to anticipate later changes in law)
- Lile v. State, 671 N.E.2d 1190 (Ind.Ct.App.1996) (standard for reviewing PCR findings of fact and credibility)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (requires reviewing court to evaluate objective reasonableness of counsel’s performance)