Yarborough, Warden v. Gentry

Gentry (defendant) was convicted of assault with a deadly weapon after allegedly stabbing his girlfriend; he claimed the injury was accidental. Trial testimony was mixed and somewhat inconsistent, and Gentry himself falsely testified about his prior convictions. After the prosecutor accused Gentry of telling the jury a 'pack of lies,' defense counsel's closing argument was somewhat disjointed but centered on the theme that no one — jury, prosecutor, or defense — had actually witnessed the crime, so everything was speculation. The jury convicted Gentry, and he argued the weak closing deprived him of effective assistance of counsel; the Ninth Circuit agreed and granted habeas relief.

Whether a closing statement by defense counsel violates the Sixth Amendment right to effective counsel because it is deficient in some respects, and whether deference to state courts on such matters should be set aside.