Laux v Zatecky

Dist. Ct. did not err in denying defendant’s habeas petition challenging his life sentence without possibility of parole on murder charge on ground that his trial counsel was ineffective for failing to thoroughly investigate and present certain evidence of defendant’s childhood as mitigation during sentencing hearing. Trial counsel’s performance during sentencing hearing was reasonable, where counsel: (1) made efforts to educate himself about life-without-possibility-of-parole procedures; (2) cross-examined experts to help elicit mitigating details; and (3) called two lay witnesses, in addition to defendant, to discuss defendant’s lack of criminal history, as well as his mental instability and favorable traits as father, Catholic and husband. Moreover, defendant’s proposed additional evidence added only de minimus value to defendant’s claim of disadvantaged childhood and would not have altered sentencing profile presented to jury, especially where evidence of defendant’s childhood and background failed to show significant hardship.