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JONES v. CLARKE, NO. 14-6590

Decided: April 22, 2015

The Fourth Circuit held that a federal trial court’s order granting habeas corpus based on a claim of ineffective assistance of counsel must be vacated and the petition remanded for dismissal.

In state court, Jones waived a jury trial after being charged with grand larceny and breaking and entering. During the period that Jones was awaiting trial, the victim visited Jones in jail, informed him that police had his fingerprints, and asked why he did it, to which Jones replied he made a mistake. While the only evidence explicitly connecting Jones to the crime, which involved the breaking of a window and theft of a television and other items, was a single fingerprint on the broken glass offered without the testimony of a fingerprint analyst, Jones’s attorney failed to object to the hearsay evidence. The judge ultimately held that the fingerprint evidence in conjunction with Jones’s admission to the victim, which his attorney argued was ambiguous and not a clear admission, constituted enough evidence to find Jones guilty beyond a reasonable doubt. The Supreme Court of Virginia ultimately denied Jones’s habeas petition, prompting Jones to file a petition with a federal trial court, which ultimately granted the relief on the grounds that the Supreme Court of Virginia unreasonably applied the Strickland v. Washington, 466 U.S. 668 (1984), standard in rejecting Jones’s ineffective assistance of counsel claim.

In vacating the trial court’s order, the Fourth Circuit noted that because the state supreme court had adjudicated the matter on the merits, a federal court lacked the ability to grant habeas relief unless the state court’s adjudication was (1) contrary to federal laws as determined by the United States Supreme Court or (2) based on an unreasonable determination of facts in light of the evidence. Additionally, the court noted that an ineffective assistance of counsel claim required both a showing of deficient performance by counsel and a resulting prejudice to the defendant. The court reasoned that here the Strickland standard was reasonably applied because there was no reasonable, substantial likelihood that the result would have differed in the absence of the fingerprint evidence because of Jones’s jailhouse admission to the victim. Since the judge explicitly found Jones’s statement to the victim to be an admission, the court must presume that the factual finding was correct. Accordingly, even if the fingerprint evidence had been excluded, Jones was not prejudiced by that evidence because of his jailhouse admission.

Dissent: The dissent noted that trial counsel did very little in the way of actually defending Jones, surrendering the Sixth Amendment right of confrontation and ultimately putting up no fight at all. The dissent expounded the trial judge’s statement that the fingerprint evidence combined with the jailhouse admission gave rise to guilt beyond a reasonable doubt as follows:  the logical conclusion of such reasoning was that the lack of fingerprint evidence would give rise to a reasonable probability of Jones’s acquittal.

Full Opinion

Kayla M. Porter