Snow v. Pfister

Dist. Ct. did not err in denying defendant’s habeas petition challenging his murder conviction on grounds that his trial counsel was ineffective for failing to impeach certain witnesses who were at murder scene and for representing him while suffering from alcoholism. Defendant procedurally defaulted certain aspects of his ineffective assistance of counsel claim, where he failed to include in state court petition for leave to appeal precise contentions as to why his trial counsel was ineffective. As to defendant’s non-defaulted claim that counsel should have impeached one witness who placed defendant at murder scene, defendant could not show that any failure to impeach said witness was prejudicial, where credibility of said witness was undermined by other evidence. Also, counsel’s personal problems with alcoholism, without evidence of any specific alcohol-related incident, did not constitute ineffective assistance of counsel. Too, Dist. Ct. could properly reject defendant’s claim that prosecutor withheld helpful evidence regarding existence of sentencing deals given to certain witnesses testifying on behalf of State, where all court documents regarding said sentences were available to public. Moreover, other withheld evidence pertaining to fact that one witness merely sought deal with prosecutor would not have changed outcome of trial.