Samaniego v. State

Summary

The Court affirmed the denial of postconviction relief because Samaniego failed to show prejudice from either alleged attorney error. The prosecutor's question about whether the detective had interviewed or attempted to interview Samaniego did not, without indication that the conduct was post-arrest or involved an invocation of silence or counsel, violate the Fifth Amendment or constitute prosecutorial misconduct. A new-trial motion based on jurors' deliberations about Samaniego's failure to testify would also have been unsuccessful because the evidence was barred by the rule governing juror testimony and declarations. No separate opinions were filed.