Metts v. United States

Summary

The District of Columbia Court of Appeals affirmed Anthony W. Metts's convictions for assault-related offenses, possession of a firearm during a crime of violence, and carrying a pistol without a license. The court held that the trial court's curative instruction regarding a witness's reference to Metts's prior imprisonment was adequate and that denial of a mistrial was not an abuse of discretion. The court also affirmed denial of Metts's D.C. Code § 23-110 motion and evidentiary hearing request, finding that his ineffective-assistance allegations and proffered witness statements did not warrant relief.

Holdings

1. The trial court did not abuse its discretion in denying a mistrial because the witness's reference to Metts's imprisonment was neutralized by a prompt, complete, and unambiguous curative instruction, and the government's evidence was strong.
2. A § 23-110 hearing is ordinarily presumed appropriate, but is not required when the motion presents vague or conclusory allegations, palpably incredible claims, or allegations that would not warrant relief even if true.
3. The denial without a hearing of Metts's § 23-110 motion was reviewed for abuse of discretion and was properly affirmed.
4. Metts failed to state a cognizable ineffective-assistance claim based on counsel's alleged failure to communicate the renewed plea offer because he alleged only that he would have reviewed the offer, not that he would have accepted it or suffered prejudice.
5. The trial court did not abuse its discretion by denying a hearing on the claim that trial counsel's poor health rendered counsel ineffective.
6. A defendant's inability to obtain affidavits from reluctant witnesses does not itself require a § 23-110 hearing; the defendant may seek court-approved discovery under Rule 6.

Questions Presented

1. Whether the trial court abused its discretion by denying a mistrial after a witness referred to Metts's prior imprisonment and by giving a curative instruction.
2. Whether the trial court abused its discretion by denying Metts's D.C. Code § 23-110 motion and refusing to hold an evidentiary hearing on his ineffective-assistance claims.
3. Whether the alleged failure to communicate a renewed plea offer established prejudice warranting a § 23-110 hearing.
4. Whether trial counsel's alleged poor health warranted a § 23-110 evidentiary hearing.

Disposition

affirmed