State ex rel. Williams v. State

Summary

The Louisiana Supreme Court denied Deairen Williams’s application for post-conviction relief, holding that he failed to establish ineffective assistance of counsel under Strickland v. Washington. The attached district court order rejected claims concerning counsel’s investigation, severance of offenses, sentencing, actual innocence, and entitlement to an evidentiary hearing, and stated that Williams had exhausted his state collateral-review remedies absent a narrow exception for a successive application.

Holdings

1. Williams was not entitled to post-conviction relief because he failed to prove both deficient performance and prejudice. The record did not support his claim that counsel failed to subpoena DNA evidence, and the alleged 911-tape evidence did not establish a reasonable probability of a different result.
2. Williams's freestanding actual-innocence claim did not provide a basis for post-conviction relief because he did not present new, material, noncumulative, and conclusive evidence meeting the extraordinarily high standard described by Louisiana jurisprudence.
3. Williams was not entitled to post-conviction relief based on counsel's failure to pursue severance because the offenses were legally joinable and the choice of pretrial motions was a matter of trial strategy.
4. Williams was not entitled to post-conviction relief because he failed to show that counsel's failure to file a motion to reconsider sentence caused prejudice.
5. After Williams's application had been fully litigated, he had exhausted his right to state collateral review unless he could establish one of the narrow exceptions authorizing a successive application.

Questions Presented

1. Whether Williams established ineffective assistance of counsel based on counsel's alleged failure to investigate, interview, or subpoena evidence.
2. Whether Williams established ineffective assistance based on counsel's failure to seek severance of the offenses.
3. Whether Williams established ineffective assistance based on counsel's failure to file a motion to reconsider sentence.
4. Whether a freestanding, non-DNA-based actual-innocence claim provided a basis for post-conviction relief.
5. Whether Williams was entitled to an evidentiary hearing on his post-conviction claims.
6. Whether Williams had exhausted his right to state collateral review after full litigation of his application.

Disposition

writ_denied