Brandon Hobbs v. Mark Hooks

Summary

Brandon Hobbs v. Mark Hooks (6th Cir. 2018) – Habeas corpus; ineffective assistance of counsel. The Sixth Circuit affirmed denial of habeas relief, holding that the state appellate court reasonably applied Strickland v. Washington when it concluded that trial counsel’s decision to admit prejudicial evidence of Hobbs’s drug dealing and gun possession was a legitimate trial strategy to bolster credibility and support a self-defense claim. Under AEDPA’s double deference, the state court’s factual finding that counsel’s conduct was strategic rather than ignorant was not unreasonable, and the independent claim regarding failure to request a curative instruction was procedurally barred.

Holdings

1. The state appellate court's conclusion that Hobbs's trial counsel's performance fell within the wide range of reasonable professional assistance was neither contrary to clearly established federal law nor based on an unreasonable determination of facts.

Questions Presented

1. Whether the state appellate court unreasonably applied Strickland v. Washington in concluding that Hobbs's trial counsel provided effective assistance by allowing evidence of Hobbs's prior drug dealing and gun possession as a legitimate trial strategy.

Disposition

affirmed