U.S. Court of Appeals for the Fourth Circuit, 2001

The Fourth Circuit affirmed summary judgment for the Commissioner, concluding that substantial evidence supported the determination that Mastro was not disabled under the Social Security Act.

The court reversed the district court’s grant of habeas relief on Rose’s ineffective-assistance claim, concluding that counsel’s strategic choice not to introduce damaging evidence of Rose’s sexual disorders was reasonable and that Rose did not show prejudice.