Warren v. Baenen

Dist. Ct. did not err in denying defendant’s habeas petition challenging his guilty plea to reduced first-degree reckless homicide charge where defendant alleged that his trial counsel was ineffective by failing to investigate certain witnesses who could have supported his self-defense claim by testifying that they witnessed struggle in car in which both defendant and victim occupied. Proffered testimony did not add anything new to defendant’s hypothetical defense, and thus defendant was unable to show that said evidence would have changed counsel’s advice to plead guilty to instant reduced charge. Ct. similarly rejected defendant’s contention that: (1) trial counsel should have requested mental evaluation of defendant to determine defendant’s competency to enter into guilty plea where, although defendant had been diagnosed with mental illness, there was no medical evidence to suggest that he was not competent to understand instant legal proceedings; and (2) his guilty plea was unknowing because trial counsel failed to advise him that he had ability to pursue self-defense claim.