HABEAS CORPUS OUTLINE

Ground One – Ineffective Assistance of Trial Counsel

• Failure to object to inadmissible prior conviction (Rule 609(b))

• Failure to present mitigating evidence at sentencing

• Failure to act on late disclosure of Facebook messages

• Incorrect advice on probation eligibility and sentencing options

• Failure to pursue plea negotiation or judicial consideration

• Failure to investigate alternate suspect (Geoffrey Jackson)

• Failure to cross-examine and impeach key witnesses

• Resulting cumulative prejudice

Ground Two – Prosecutorial Misconduct & Due Process Violations

• Late disclosure of Facebook messages
  

• Admission of unauthenticated electronic evidence
  

• Burden-shifting regarding authenticity
  

• Misleading presentation of prior conviction at sentencing
  

Ground Three – Ineffective Assistance of Appellate Counsel

• Failure to challenge false factual finding adopted on appeal
  

• Failure to address contradictory stance on Facebook messages’ importance
  

• Failure to raise preserved constitutional burden-shifting error
  

Ground Four – Improper Grand-Jury Presentation

• Misleading use of prior conviction label before grand jury
  

• Request for in-camera review of grand-jury materials
  

V. Cumulative Effect of Errors & Misleading Effect of Prior-Offense Label

• Combined prejudicial impact under Ex parte Flores
  

• Influence of “sexual assault of a child” label across proceedings

VI. Exhibits A-Z VII. Proposed Findings of Fact and Conclusions of Law

 A. Findings of Fact (recitation of key factual determinations)
B. Conclusions of Law tied to each ground for relief
C. Recommendation for relief