Seventh Circuit Denies Habeas Relief. Proof That Trial Attorney Suffered From Mental Illness and Was Subsequently Disbarred by Itself Is Not Enough for an Ineffective Assistance Claim.

In this case which involved a murder conviction in Central Illinois, the Seventh Circuit reviewed the denial of habeas corpus relief. They concluded that there was insufficient evidence of ineffective assistance of counsel. The fact that his attorney was disbarred and the fact that he had certain mental illness issues, without more, is insufficient.

They also concluded that there was no Brady violation in this case either. The omissions were considered not enough given the weight of the evidence against the defendant to changed the outcome.

The case is Snow v. Pfister.

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