Taylor v. Metoyer

Summary

The Supreme Court of Georgia affirmed the grant of habeas corpus relief to Shaun Metoyer, concluding that he received ineffective assistance of appellate counsel. The court held that appellate counsel pursued untenable claims, inadequately presented other claims, and failed to raise a stronger ineffective-assistance claim concerning trial counsel's failure to impeach two cooperating co-defendants regarding their plea agreements and motives.

Holdings

1. Metoyer established ineffective assistance of appellate counsel because counsel performed deficiently and the deficiency prejudiced the appeal.
2. Trial counsel's failure to cross-examine the co-defendants about the actual terms of their plea agreements and their misrepresentations about those agreements constituted deficient performance and prejudiced Metoyer's defense; appellate counsel was ineffective for failing to raise that claim.
3. The habeas court's findings were supported by the record and legally sufficient to establish ineffective assistance of appellate counsel.

Questions Presented

1. Whether appellate counsel provided ineffective assistance by presenting frivolous or inadequately supported claims on direct appeal.
2. Whether appellate counsel was ineffective for failing to raise trial counsel's failure to cross-examine the State's key co-defendant witnesses concerning their plea agreements and motives to testify.
3. Whether the habeas court's findings of deficient performance and prejudice were clearly erroneous or legally insufficient.

Disposition

affirmed