Duffi v. State

Summary

The North Dakota Supreme Court affirmed the denial of Koffi Mande Yi Noum Duffi’s application for postconviction relief. The court held that Duffi failed to establish prejudice under the Strickland standard in his claim that counsel provided ineffective immigration advice concerning his guilty pleas and summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Holdings

1. Duffi failed to establish ineffective assistance of counsel because the district court determined that he did not satisfy the Strickland test.
2. Duffi failed to establish prejudice resulting from the purportedly deficient representation.

Questions Presented

1. Whether Duffi established ineffective assistance of counsel based on allegedly incorrect immigration advice concerning the consequences of his guilty pleas.
2. Whether Duffi established prejudice by showing a reasonable probability that, absent counsel's alleged errors, he would not have pleaded guilty and would have insisted on going to trial.

Disposition

affirmed