Charles E. McDowell Jr. v. Arthur Calderon, Warden
Court of Appeals for the Ninth Circuit
1Per curiam
Charles McDowell was convicted of murder and sentenced to death by the State of California. In December 1990, he filed a petition for writ of habeas corpus in the Central District of California. Among other issues, he raised claims of ineffective assistance of counsel. The district court recognized that McDowell’s ineffective assistance claims waived his attorney-client privilege as to those matters pertaining to the attorney’s representation of McDowell at trial. See, e.g., Wharton v. Calderon, 127 F.3d 1201, 1203 (9th Cir.1997). However, the district court did not simply release the…
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