Jan G. v. Commissioner of Correction

Syllabus

The respondent Commissioner of Correction appealed, on the granting of certification, from the habeas court's judgment granting in part the petitioner's petition for a writ of habeas corpus. The petitioner had previ- ously been convicted of murder and assault of an elderly person in the third degree after an incident in which he consumed a large quantity of cocaine and attacked his parents in their home, killing his father. The respondent claimed, inter alia, that the court improperly concluded that the petitioner's trial counsel, M, had violated the petitioner's sixth amendment right to autonomy to decide the fundamental objectives of his defense, as established in McCoy v. Louisiana (584 U.S. 414). Held: The habeas court improperly concluded that M violated the petitioner's sixth amendment right to autonomy under McCoy, as M honored the petitioner's not guilty plea and did not concede his guilt at his criminal trial and, thus, McCoy was inapplicable to the petitioner's claim, and this court declined to extend the holding of McCoy to conclude that M, by raising a defense of extreme emotional distress on the petitioner's behalf, had conceded his guilt. The habeas court improperly concluded that M rendered ineffective assistance by failing to raise a defense of mental disease or defect at the petitioner's criminal trial, as M's decision to forgo that defense was a reasonable trial strategy based on the information available to him at the time he made it and, thus, the petitioner did not satisfy his burden of demonstrating that M's performance was constitutionally deficient. Argued June 4, 2025—officially released January 13, 2026