People v. Ramchair

Summary

The New York Court of Appeals held that the defendant was not denied meaningful representation when appellate counsel did not separately argue that the trial court should have granted a mistrial. The court concluded that counsel had raised related issues, presented two substantial claims, and could reasonably have chosen to emphasize the right-to-present-a-defense claim rather than the mistrial issue. The court affirmed denial of the defendant's coram nobis petition.

Holdings

1. The omission did not constitute ineffective assistance of appellate counsel because counsel raised the substantive grounds underlying the mistrial motion in another appellate claim, presented two strong claims, and could reasonably have chosen to emphasize the right-to-present-a-defense argument rather than separately focusing on the mistrial application.

Questions Presented

1. Whether appellate counsel provided ineffective assistance by failing to argue separately that the trial court erred in denying defendant's motion for a mistrial.
2. Whether the Appellate Division properly denied defendant's petition for a writ of error coram nobis.

Disposition

affirmed