Washington v. State

Summary

The Rhode Island Supreme Court affirmed the Superior Court's denial of Jeffrey Washington's post‑conviction relief applications, holding that his trial counsel provided effective assistance and that the trial judge did not err by forgoing a colloquy on Washington's waiver of the right to testify. The Court applied the Strickland two‑part test de novo and found no performance deficiency or prejudice on any of the four issues raised. It also reiterated that a trial judge is not required to conduct a sua sponte colloquy to verify a waiver of the right to testify.