Conley v. Reagle

Summary

The United States District Court for the Southern District of Indiana denied Andrew Conley's petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court held that the Indiana state courts reasonably rejected Conley's claims that his guilty plea was involuntary and that trial counsel provided ineffective assistance, and it denied a certificate of appealability.

Holdings

1. The Indiana Court of Appeals reasonably concluded that Conley did not receive ineffective assistance in connection with his guilty plea. The record supported findings that Conley insisted on pleading guilty, counsel reasonably believed a plea offered the best chance to avoid life without parole, and counsel did not promise that Conley would avoid that sentence.
2. The Indiana Supreme Court reasonably rejected Conley's claim that counsel were ineffective for failing to present additional evidence or argument concerning his age, juvenile brain development, Roper, and Graham.
3. The Indiana Supreme Court reasonably concluded that counsel were not ineffective for failing to retain an expert to rebut the prosecution pathologist's testimony concerning whether the victim was alive when the plastic bag was placed over his head.
4. The Indiana Supreme Court reasonably concluded that counsel did not perform deficiently in challenging Dr. Daum's mental-health testimony.
5. The Indiana Supreme Court reasonably concluded that counsel were not ineffective for failing to obtain additional jail records and related testimony concerning Conley's mental health.
6. The Indiana Supreme Court reasonably concluded that counsel were not ineffective for failing to call every proposed character or mental-health witness.
7. Conley's guilty plea was not shown to be unknowing, unintelligent, or involuntary, and the Indiana Court of Appeals reasonably applied the governing standard in rejecting that claim.
8. Conley was not entitled to habeas relief because the state courts did not unreasonably apply clearly established federal law or unreasonably determine the facts.
9. A certificate of appealability shall not issue because reasonable jurists could not disagree with the resolution of Conley's claims and the claims do not warrant further proceedings.

Questions Presented

1. Whether trial counsel rendered ineffective assistance by advising Conley to plead guilty rather than proceed to trial, including on a possible guilty-but-mentally-ill defense.
2. Whether trial counsel rendered ineffective assistance by failing to present additional evidence and argument concerning juvenile brain development, Conley's age, and Roper, Graham, and Miller.
3. Whether trial counsel rendered ineffective assistance by failing to obtain expert testimony rebutting the prosecution pathologist's testimony.
4. Whether trial counsel rendered ineffective assistance by inadequately challenging the testimony of Dr. Daum or failing to obtain another mental-health expert.
5. Whether trial counsel rendered ineffective assistance by failing to obtain jail records and related personnel testimony concerning Conley's mental health.
6. Whether trial counsel rendered ineffective assistance by failing to call additional character and mental-health witnesses at sentencing.
7. Whether Conley's guilty plea was knowing, intelligent, and voluntary.
8. Whether Conley was entitled to federal habeas relief under AEDPA.
9. Whether a certificate of appealability should issue.

Disposition

dismissed