Eric Kurt Patrick v. State of Florida

Summary

The court affirmed the denial of postconviction relief on Patrick's claim that trial counsel was ineffective for failing to challenge a juror who was actually biased against him. The court held that competent, substantial evidence supported the finding that counsel made a strategic choice to retain the juror because he could benefit Patrick during both the guilt and penalty phases, and that the strategy was objectively reasonable. The court distinguished the prejudice inquiry from the separate deficiency inquiry under the governing ineffective-assistance framework.