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Name: Anderson v. Calderon
Court: US Court of Appeals
District 9 Cir
Opinion Date: 11/17/2000
Subsequent History: None

There was no ineffective assistance of counsel where trial counsel did not meet in person with Anderson prior to the trial. Counsel’s investigators met regularly with Anderson and worked under his direction. Counsel communicated regularly with Anderson by telephone. The relatively elastic standards of Strickland v. Washington (1984) 466 U.S. 668 make it clear that there is no one correct formula for effective assistance which would include personal visits. Counsel was not ineffective for conceding guilt, where it was a tactical decision to avoid the ultimate penalty. Penalty phase issues are not summarized here.