james chambers
James Chambers, State v. Chambers, 671 S.W.2d 781 (Mo. banc 1984)
Improper Denial of Self-Defense Instruction
James Chambers was convicted and sentenced to death for shooting and killing Steve Oestricker, after a bar fight. On direct appeal the Missouri Supreme Court reversed Chambers’ conviction and death sentence because the trial court refused to instruct the jury on self-defense, even though the evidence was sufficient to support such an instruction.
James Chambers, Chambers v. Armontrout, 907 F.2d 825 (8th Cir. 1990) (en banc) (second trial)
Ineffective Assistance of Counsel, Guilt Phase
Chambers was convicted and sentenced to death a second time. In federal habeas, the Eighth Circuit reversed the district court’s denial of habeas relief, holding that Chamber’s trial counsel was ineffective for failing to interview and call as a witness James Jones, the only person who saw the fight outside the bar and who could have supported Chamber’s self-defense claim. The state had argued that trial counsel’s decision not to interview Jones was reasonable because Jones’ testimony at Chambers’ first trial contained negative aspects. The 8th Circuit disagreed, stating that “[o]ther witnesses had testified to the negative aspects of Jones’ testimony cited by [trial counsel] as justifying his decision not to interview Jones,” and that any damaging testimony would be cumulative. 907 F.2d at 830. “[R]easonable counsel would have interviewed Jones to make sure that Jones was willing to repeat his earlier testimony that Oestricker knocked Chambers to the ground, to satisfy himself as to the remainder of Jones’ testimony, and to assess Jones’ credibility.” Id.
The state had also argued that trial counsel’s decision was reasonable because Chambers gave his trial counsel reason to believe further investigation of Jones would be fruitless. In rejecting this argument the Eighth Circuit observed that Chambers’ statement to counsel “indicates only that a defendant with an eighth grade education, relying on information provided by [trial counsel], agreed with [trial counsel’s] decision not to call Jones. Whether or not Chambers agreed with the decision not to call Jones does not make that decision any more reasonable or the investigation fruitless or harmful.” Id. at 831.