Small v. Woods

Federal 7th Circuit Court
Criminal Court
Federal Habeas Corpus
Citation
Case Number: 
No. 23-1397
Decision Date: 
July 29, 2025
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Vacated and remanded.
Judge: 
JACKSON-AKIWUMI

Petitioner was convicted in state court of one count of battery and two counts of attempted murder and he was sentenced to 40 years in prison. On federal habeas review, petitioner argued that he was denied the effective assistance of counsel, arguing his trial counsel incorrectly advised him about the potential length of his sentence, which led him to reject a plea offer and to instead proceed to trial. The Seventh Circuit found that the district court made an unreasonable determination of fact when evaluating the claim and remanded with instructions to perform an evidentiary hearing. (ROVNER and MALDONADO, concurring)