Summary
The Supreme Court of Utah affirmed summary judgment for the State on Ronald Lafferty's claims for post-conviction relief. The court held that Lafferty failed to present facts establishing genuine issues for trial, including regarding ineffective assistance of trial and appellate counsel, mitigation investigation, jury sequestration, prosecutorial misconduct, and related constitutional claims.
Topics
Practice areas
Questions Presented
- Whether Lafferty produced evidence creating a genuine issue of material fact on his ineffective-assistance claims concerning jury sequestration, mitigation investigation, counsel qualifications, prosecutorial argument, and change of venue.
- Whether claims that were raised or could have been raised on direct appeal were procedurally barred under the Utah Post-Conviction Remedies Act.
- Whether alleged time and funding constraints prevented post-conviction counsel from complying with ABA guidelines and entitled Lafferty to relief.
- Whether later testimony by a psychologist disavowing or modifying the theory of situational competence constituted newly discovered material evidence warranting relief.
- Whether counsel's prior representation of Lafferty's co-defendant created an actual, constitutionally actionable conflict of interest.
Holdings
- Lafferty failed to establish either deficient performance or prejudice under Strickland. His allegations and unsupported assertions did not create a genuine issue for trial.
- Claims that were raised or could have been raised on direct appeal are barred from post-conviction review unless an applicable statutory exception, such as ineffective assistance of counsel, is properly pleaded and supported.
- Alleged noncompliance with ABA guidelines, including limitations on time or funding, does not by itself establish entitlement to post-conviction relief.
- The alleged later testimony by Dr. Golding did not satisfy the statutory requirements for newly discovered evidence because Lafferty failed to provide supporting proof and, in any event, the evidence was merely impeachment evidence and would not dictate a different result.
- Prior representation of a co-defendant does not establish an unconstitutional conflict absent proof that an actual conflict adversely affected counsel's performance by forcing choices favoring the former client to the detriment of the defendant.
Key quotations
“We affirm, holding that Lafferty failed to advance facts showing a genuine issue for trial.” (175 P.3d at 530)
“The qualifications outlined in rule 8 constitute our attempt to decrease the likelihood that capital defendants will receive representation from inexperienced attorneys; however, compliance with these requirements is not constitutionally mandated.” (175 P.3d at 538)
“We consequently affirm the district court's summary judgment on this claim.” (175 P.3d at 545)
Factual background
In 1984, Lafferty and his brother forcibly entered the home of Lafferty's sister-in-law, severely beat her, and killed her fifteen-month-old daughter. Lafferty was convicted of two counts of first-degree murder and related offenses, sentenced to death, and later obtained federal relief because the state trial court had used an incorrect competency standard. After a 1996 retrial and renewed convictions and death sentences, Lafferty filed a post-conviction petition alleging deficient representation, newly discovered evidence concerning his competency, procedural errors, and a conflict arising from counsel's prior representation of his brother.
Procedural history
Lafferty was convicted and sentenced to death after a 1996 retrial, and the Utah Supreme Court affirmed those convictions in 2001. He filed a post-conviction petition asserting numerous claims, including ineffective assistance, procedural-bar exceptions, inadequate post-conviction representation, newly discovered evidence, and conflict of interest. The post-conviction court granted the State summary judgment on all claims, and Lafferty appealed. The Utah Supreme Court affirmed.