Anderson v. Kelley
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Summary

Anderson claimed counsel missed key mitigation—teen brain limits, PTSD, and fetal alcohol disorder. The Eighth Circuit held counsel’s investigation and expert use were reasonable, so the assistance was not constitutionally deficient.

2019 | Federal Juristiction

Anderson v. Kelley

Keywords Anderson; counsel; mitigation; teen brain limits; PTSD; fetal alcohol disorder; Eighth Circuit; investigation; expert use; ineffective assistance
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Summary

Anderson contended that legal counsel overlooked significant mitigating factors, specifically limitations of the adolescent brain, post-traumatic stress disorder, and fetal alcohol disorder. However, the Eighth Circuit concluded that counsel's investigation and use of expert testimony were reasonable. Therefore, the court found no basis for a claim of ineffective assistance of counsel.

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Summary

An individual named Anderson asserted that their legal counsel failed to present significant mitigating evidence during the proceedings. This evidence reportedly included factors such as the developmental limitations of an adolescent brain, the presence of post-traumatic stress disorder (PTSD), and fetal alcohol spectrum disorder. However, the Eighth Circuit Court of Appeals concluded that the defense counsel's investigation and their engagement of expert witnesses were appropriate. As a result, the court determined that there were no grounds to claim ineffective assistance from the legal counsel.

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Summary

Mr. Anderson argued that his legal representation failed to present crucial mitigating factors during his case. These factors included limitations of the adolescent brain, the presence of post-traumatic stress disorder (PTSD), and fetal alcohol spectrum disorder. However, the Eighth Circuit Court determined that the lawyer's investigation and use of expert testimony were reasonable. Consequently, the court concluded there was no evidence of ineffective assistance of counsel.

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Summary

Anderson said his lawyer did not share important facts. These facts were about how a young person's brain works, a stress problem, and issues from alcohol use before birth. The court called the Eighth Circuit said the lawyer looked into the case well. The court also said the lawyer used experts the right way. So, the court decided the lawyer did a good job.

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Footnotes and Citation

Cite

Anderson v. Kelley, 938 F.3d 949 (8th Cir. 2019)

Highlights