Bellamy v. Cogdell
United States Court of Appeals for the Second Circuit
974 F.2d 302 (1992)
Bellamy (defendant), charged with murder, was represented by an attorney who, months before trial, faced disciplinary proceedings after a doctor reported he suffered physical and emotional impairments rendering him incompetent to practice. The attorney assured the disciplinary committee he could still handle Bellamy's case (his only active matter) with help from a second attorney, and privately told the trial judge his condition had improved, but the second attorney never actually assisted at trial. Bellamy was convicted, and two months later his attorney was suspended from practice. Bellamy moved to vacate his conviction for ineffective assistance; the state courts, after a hearing, found the attorney had been competent at trial and upheld the conviction. The federal district court deferred to that finding and denied relief. Bellamy appealed.
Whether, when a convicted criminal defendant claims ineffective assistance of counsel, federal courts must defer to a state court's factual findings on trial counsel's competency made after a state hearing.