Payne v. State

Summary

The court affirmed Payne’s convictions, holding that the evidence sufficiently authorized the jury to find that he personally participated in or was a party to the child’s fatal injuries and that the alternative hypothesis that the child’s mother acted alone was unreasonable. The court also upheld the exclusion of the mother’s drug-use evidence, the refusal to give a separate grave-suspicion instruction, and the rejection of Payne’s ineffective-assistance claim. The ineffective-assistance claim failed because counsel’s decision not to seek severance was a reasonable trial strategy.