MD: No IAC where def counsel reasonably concluded 4A lacked merit

Defense counsel made reasonable choices not to pursue two Fourth Amendment challenges because it was likely that they’d lose. Williams v. State, 2026 Md. App. LEXIS 288 (Mar. 17, 2026)* (unreported):

Considered in the proper context of Perkins, Scott, and Brown, we conclude that Williams failed to show that his trial counsel performed deficiently in failing to move to suppress the evidence recovered as a result of the warrantless search of Ms. Bobbitt’s home. To begin with, Williams gave police a different home address than Ms. Bobbitt’s when he was arrested. Trial counsel could have decided reasonably that it would be difficult to prove that Williams had standing to challenge the warrantless entry into Ms. Bobbitt’s home, an entry to which she consented seemingly.

Furthermore, even had it been possible for trial counsel to overcome the hurdle of questionable standing, it is not enough to show (as Redmond, with the benefit of 20-20 hindsight, would illustrate after Williams’s trial) that a motion to suppress might have or probably would have succeeded. Rather, to show deficient performance, Williams was required to prove that it was unreasonable objectively for trial counsel to fail to move to suppress the evidence in his case, a substantially greater showing. See Strickland, 466 U.S. at 688 (explaining that “the defendant must show that counsel’s representation fell below an objective standard of reasonableness”).