Ex parte Brayden Channing Coin

Summary

The Texas Court of Appeals for the Second District affirmed the denial of Brayden Channing Coin’s application for habeas relief from deferred adjudication community supervision. The court held that the habeas court’s factual findings supported its conclusions that counsel’s alleged failures to investigate Fortnite’s release availability, challenge adult-court jurisdiction, and advise Coin about the significance of his age did not establish ineffective assistance or prejudice.

Holdings

1. Coin failed to establish prejudice from counsel's alleged failure to investigate because he did not show that the investigation would have produced evidence reasonably capable of changing the result.
2. Coin failed to establish ineffective assistance based on counsel's failure to seek a transfer because he did not show that a transfer motion would have been meritorious or granted.
3. Coin failed to establish that counsel's advice was deficient or that any alleged failure prejudiced his guilty plea.
4. The court of appeals was required to defer to the habeas court's supported factual findings, which were dispositive of Coin's ineffective-assistance claims.

Questions Presented

1. Whether trial counsel was ineffective for failing to investigate Fortnite's prerelease availability.
2. Whether trial counsel was ineffective for failing to move to transfer the case from adult criminal court to juvenile court based on the alleged weakness of the State's evidence concerning the offense date and Coin's age.
3. Whether trial counsel was ineffective for failing to advise Coin about the jurisdictional and evidentiary significance of his age, allegedly rendering his guilty plea involuntary.
4. Whether the habeas court abused its discretion by denying relief based on factual findings credited from the record and trial counsel's verifications.

Disposition

affirmed