Gypsy Allen Codianna, Petitioner and Appellant v. Lawrence Morris

Summary

The Utah Supreme Court affirmed denial of postconviction relief from the petitioner's murder conviction. It held that four trial-error claims were not cognizable in habeas because they were known or should have been known at trial or on direct appeal, that undisclosed evidence did not create a reasonable doubt of guilt, and that counsel's performance was constitutionally adequate and nonprejudicial. Justice Stewart concurred in the result but would treat procedural default as only one factor in deciding whether habeas review is necessary to prevent a fundamental injustice.