State v. Haffey

Summary

The Montana Supreme Court affirmed Stephen Patrick Haffey’s convictions for felony assault with a weapon and driving under the influence. The court rejected his ineffective-assistance, evidentiary, and cumulative-error claims and held that the District Court properly admitted and limited testimony concerning Haffey’s recorded conversation with his father.

Holdings

1. Haffey failed to establish ineffective assistance of counsel because the record showed that counsel's challenged decisions were objectively reasonable under the circumstances, and Haffey did not demonstrate deficient performance sufficient to warrant relief.
2. The District Court did not err by allowing Haffey's father to read a limited portion of the transcript concerning Haffey's statement that the collision was accidental and that he could not stop in time.
3. Cumulative error did not prejudice Haffey's right to a fair trial.

Questions Presented

1. Whether Haffey was denied effective assistance of counsel because trial counsel allegedly failed to pursue an alternative-driver theory, failed to make an opening statement, and failed to call two rebuttal witnesses.
2. Whether the District Court erred by admitting limited testimony from Haffey's recorded conversation with his father while Haffey was in custody.
3. Whether cumulative error deprived Haffey of a fair trial.

Disposition

affirmed