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Ineffective Assistance of Counsel

State v. Michael A. Clements, 2010AP1978-CR, District 4, 10/13/11

court of appeals decision (not recommended for publication); for Clements: Steven D. Grunder, SPD, Madison Appellate; case activity

Counsel’s performance not deficient, against claims that he failed to: impeach the complainant with a prior recorded statement; object on hearsay grounds to admissibility of her statement to a school counselor; object to the State’s closing-argument characterization of the sole defense witness; present a consistent theory of defense.

General test for reviewing IAC claims recited, ¶¶13-15, otherwise there’s not much of note in this highly fact-specific result.

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