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Criminal Law-Post-Conviction Relief-Ineffective Assistance of Counsel

Staff Report//April 22, 2026//

Criminal Law-Post-Conviction Relief-Ineffective Assistance of Counsel

Staff Report//April 22, 2026//

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Defendant appealed the denial of his motion for post-conviction relief, which alleged that his trial counsel was ineffective for failing to adequately advise defendant about testifying at trial, failing to investigate and present expert evidence on false confessions and failing to voir dire the jury regarding their ability to evaluate defendant’s interrogation video.     

Where defense counsel made a reasonable strategic decision to try to minimize the effects of defendant’s confession, the trial court did not err in concluding that counsel had not provided deficient representation. Furthermore, defendant failed to present evidence that any biased jurors were empaneled, resulting in no prejudice from the lack of voir dire on confessions.  

Judgment is affirmed.  

Harris v. State (MLW No. 84649/Case No. WD87651 – 27 pages) (Missouri Court of Appeals, Western District, Gabbert, J.) Appealed from circuit court, Jackson County, Phillips, J. (Damien De Loyola, Kansas City for appellant) (Renee Warden, Jefferson City for respondent) 


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