Jehiel Fields v. State of Tennessee

Summary

The Tennessee Supreme Court held that State v. Burns did not change the standard of appellate review for denials of post-conviction relief based on allegations of ineffective assistance of counsel. Reaffirming that such claims are mixed questions of law and fact subject to de novo review, the Court clarified that under Rule 13(d) a trial court's findings of fact are reviewed de novo with a presumption of correctness unless the preponderance of the evidence is otherwise, while the trial court's conclusions of law receive no deference or presumption. Because the Court of Criminal Appeals applied the correct standard, and because Fields' claim failed on the merits — counsel's identity defense was sound trial strategy and no prejudice was shown — the judgment affirming dismissal of the post-conviction petition was affirmed.