Lee A. Ridgley, Petitioner-Appellant v. State of Idaho, Respondent

Summary

The Idaho Supreme Court affirmed summary dismissal of Lee Ridgley's petition for post-conviction relief, which alleged six instances of ineffective assistance of counsel surrounding his guilty plea to lewd conduct entered sixteen days after his wife's death. Although the district court erred in dismissing the first five claims on an unstated res judicata ground without the notice required by I.C. § 19-4906(b), the Court affirmed because Ridgley offered no evidence of a causal connection between the alleged deficiencies and his plea, as Hill v. Lockhart requires. His sixth claim—that counsel failed to seek a competency evaluation—also failed because his conclusory affidavit and a psychological report prepared nine months after the plea were not admissible expert evidence of a reasonable probability that he was incompetent at the time of the plea. Review was granted from a Court of Appeals decision that had reversed dismissal of the competency claim.