Too Much of a Not-So-Good Thing: Trevino v. Davis and the Overly Deferential Strickland Standard

Note by Erin M. Morrissey

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.

About the Author

J.D./M.A. candidate 2019, Tulane University Law School; B.A. 2011, University of Kansas.


92 Tul. L. Rev. 943 (2018)