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Keywords

defendantattorneyappealhearingtrialmotionjury trial

defendantattorneyappealtrialtestimonymotionjury trial

Related Cases

Doucette v. State, 463 A.2d 741

Facts

In June of 1977, Wayne Doucette was indicted for rape and subsequently convicted in December 1977 after a jury trial. Doucette was sentenced to twelve years in prison. Following his conviction, he retained new counsel who appealed the judgment, but no post-conviction motions were filed. In August 1981, Doucette filed a pro se petition for post-conviction review, claiming ineffective assistance of trial and appellate counsel, which led to an evidentiary hearing in December 1981.

In June of 1977, Doucette was indicted for rape, Class A, 17–A M.R.S.A. § 252(1)(B) (1983). In December of 1977, Doucette was convicted after a jury trial at which Doucette was represented by retained counsel. Doucette was sentenced to serve twelve years in the Maine State Prison. At that time, Doucette retained new counsel who appealed the judgment to the Law Court. No post-conviction motions were filed by either counsel.

Issue

Did the defendant receive ineffective assistance of counsel during his trial and subsequent appeal?

Doucette contends, inter alia, that the post-conviction court erred in deciding that he was not deprived of effective assistance of defense counsel.

Rule

To establish ineffective assistance of counsel, the performance must fall 'measurably below that of an ordinary fallible attorney' and must have likely deprived the defendant of an otherwise available substantial ground of relief.

In Lang v. Murch, 438 A.2d 914 (Me.1981), we articulated the 'reasonably competent assistance' standard for determining claims of ineffective assistance of counsel. Under that standard, counsel's performance must fall 'measurably below that of an ordinary fallible attorney,' id. at 915, 916, and counsel must have 'likely deprived the defendant of an otherwise available substantial ground of relief.' Id. at 915.

Analysis

The court analyzed each claim of ineffective assistance separately, determining that while defense counsel's performance may have had deficiencies, these did not result in prejudice to the defendant's case. The court found that the decisions made by counsel were largely strategic and did not undermine the integrity of the trial.

The post-conviction justice ruled that 'even if this deficiency constituted a breach of the first prong of Lang, the petitioner has failed to prove a likely prejudicial effect on the trial outcome. At most, Gallant could have impeached the testimony of the victim's sister.' According to the justice, Gallant did not have any exculpatory information.

Conclusion

The Supreme Judicial Court affirmed the decision of the Superior Court, concluding that Doucette was not deprived of effective assistance of counsel.

We affirm the judgment of the Superior Court.

Who won?

The State prevailed in the case because the court found that the defendant did not demonstrate that he was prejudiced by any alleged deficiencies in his counsel's performance.

The post-conviction justice found that the trial justice knew about the prior relationship between the victim and the interpreter and that the justice permitted her to interpret under his 'watchful guidance' and 'no conduct on her part in any way prejudiced the petitioner.'

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