Jones v. Carlos: Failure to Investigate = Deficient

NEW YORK, N.Y. - The U.S. Court of Appeals for the Second Circuit affirmed a district court judgment granting habeas corpus relief to Maleek Jones, who was convicted of murder, on November 10, 2026. The appellate court ruled that trial counsel provided constitutionally ineffective assistance of counsel, violating the Sixth Amendment.

The Second Circuit determined that trial counsel, Leo Ahern, failed to investigate Sheila McCray, a key eyewitness whose testimony contradicted the state primary witness. McCray, a hospital nurse where the murder occurred, told police shortly after the 1992 murder that she saw only two shooters and provided descriptions that did not match Jones. Ahern knew about McCray and her statements, but he did not interview or subpoena her. Ahern relied instead on a private investigator hired by the family who lacked payment. The court concluded this failure lacked reasonable trial strategy and fell below an objective standard of reasonableness.

The court found that Jones suffered prejudice because McCray's testimony presented a reasonable probability of doubt regarding Jones guilt. The prosecution case relied heavily on the testimony of a single co-conspirator who received a plea deal. The Second Circuit ruled that the state courts rejection of Jones claim involved an unreasonable application of clearly established federal law under the Antiterrorism and Effective Death Penalty Act.

The decision reinforces defense counsel obligation to investigate and present exculpatory eyewitness testimony when it contradicts state witnesses. The court remanded the case for further proceedings, which typically result in a new trial or release if the state does not retry the defendant within a reasonable time.