Brief Fact Summary. Defendant a racketeering case filed a motion to vacate his conviction for ineffective assistance after a direct appeal was denied.
Synopsis of Rule of Law. “An ineffective-assistance-of-counsel claim may be brought in a collateral proceeding under [28 U.S.C] Section: 2255, whether or not the petitioner could have raised the claim on direct appeal.”
No matter how odd or deficient trial counsel's performance may seem, that lawyer may have had a reason for acting as he did.View Full Point of Law
Issue. Whether “claims of ineffective assistance of counsel need not be raised on direct appeal, whether or not there is new counsel and whether or not the basis for the claim is apparent from the trial record.”
Held. Yes. The Supreme Court first concluded that the Court of Appeals rule “requiring a criminal defendant to bring ineffective-assistance-of-counsel claims on direct appeal does not promote [the] objectives” of finality of judgment. The Supreme Court referenced the Strickland rule: “a defendant claiming ineffective counsel must show that counsel’s actions were not supported by a reasonable strategy and that the error was prejudicial.” The Court noted the essential problem with the direct appeal rule: “the evidence introduced at trial.