United States v. Edgar Steele

This opinion considers when a trial court should determine the merits of an ineffective assistance of counsel claim presented in a prejudgment motion for a new trial. A federal jury convicted Edgar Steele of murder-for-hire and victim tampering arising from Steele’s plan to kill his wife and mother-in-law. Steele argues that the district court erred by denying his prejudgment motion for new trial without reaching the merits of his claim of ineffective assistance of trial counsel. Although consideration of a prejudgment ineffective-assistance-of-counsel claim is appropriate in some cases, here the district court did not err by deferring consideration of Steele’s ineffective assistance claim to collateral review, when a complete record would be available.

We have jurisdiction over this appeal pursuant to 28 U.S.C. § 1291 , and we affirm the district court’s order denying the motion for new trial.

I. BACKGROUND

According to the evidence presented by the government at trial, Larry Fairfax worked as Edgar Steele’s handyman and Steele, himself a criminal defense attorney, hired Fairfax to kill Steele’s wife and mother-in-law. The government presented evidence that Steele…