In this Note, Erin M. Morrissey examines the Fifth Circuit Court of Appeals’ decision in Trevino v. Davis, 861 F.3d 545 (5th Cir. 2017), in which the court held that mitigating evidence of a defendant’s condition and character as a result of his Fetal Alcohol Spectrum Disorder diagnosis was insufficient to show an ineffective assistance of trial counsel claim.

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