Hazard v. State

Summary

The Rhode Island Supreme Court affirmed the denial of Derick Hazard's application for post-conviction relief alleging ineffective assistance of trial counsel. Hazard claimed that counsel failed to investigate a New Jersey traffic stop that might have corroborated his alibi in a murder prosecution. The court held that counsel's performance was not constitutionally deficient because Hazard and his family had not timely or credibly disclosed sufficient details about the traffic stop.

Holdings

1. Counsel's failure to investigate the traffic stop did not constitute constitutionally deficient performance because Hazard did not timely provide counsel with sufficient and reliable details to permit a meaningful investigation or a good-faith request for a continuance.
2. Because Hazard failed to establish deficient performance, the court did not need to reach the prejudice prong of the Strickland test.

Questions Presented

1. Whether trial counsel provided constitutionally ineffective assistance by failing to investigate a New Jersey traffic stop that allegedly could have corroborated Hazard's alibi.
2. Whether Hazard was entitled to post-conviction relief under the Strickland standard.

Disposition

affirmed