Saturday, April 13, 2013

Jones v. Barnes case brief

Jones v. Barnes case brief summary
463 U.S. 745 (1983)

The government obtained a writ of certiorari for review of a judgment of the United States Court of Appeals for the Second Circuit, which granted the petition of respondent prisoner for a writ of habeas corpus. The prisoner had been convicted in a New York trial of first and second degree robbery and second degree assault.

-Respondent was convicted of robbery and assault in a jury trial in a New York state court.
-Counsel was appointed to represent him on appeal.
-Respondent informed counsel of several claims that he felt should be raised, but counsel rejected most of the suggested claims, stating that they would not aid respondent in obtaining a new trial and that they could not be raised on appeal because they were not based on evidence in the record. -Counsel then listed seven potential claims of error that he was considering including in his brief, and invited respondent's "reflections and suggestions" with regard to those claims.
-Counsel's brief to the Appellate Division of the New York Supreme Court concentrated on three of the claims, two of which had been originally suggested by respondent.
-In addition, respondent's own pro se briefs were filed.
-At oral argument, counsel argued the points presented in his own brief, but not the arguments raised in the pro se briefs.
- The Appellate Division affirmed the conviction.
-After respondent was unsuccessful in earlier collateral proceedings attacking his conviction, he filed this action in Federal District Court, seeking habeas corpus relief on the basis that his appellate counsel had provided ineffective assistance.
-In granting the prisoner's petition for a writ of habeas corpus, the court of appeals determined that the decision of defense counsel to not argue a nonfrivolous issue on appeal resulted both in ineffective assistance of counsel and denied the prisoner's right of equal access to the appellate process.
-In challenging the judgment, the government argued that precedent did not mandate defense counsel to raise each and every nonfrivolous claim during an appeal, and indeed that often such a rule would impair the effectiveness of an appeal by placing too many claims before the appellate tribunal and watering down the strongest among them.

The Court found that there was no requirement that each nonfrivolous claim be raised on appeal.

-The decision regarding what issues to present was left in the discretion of counsel, who was required to represent his client to the best of his ability.
-The Court found that appellate counsel met this standard in his representation of defendant.

OUTCOME: The Court reversed the judgment which granted the prisoner a writ of habeas corpus.

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