The Court of Appeals in Campbell v. U.S. decided on January 30, 2020, in essence affirmed the trial court’s ruling and convictions denying the ineffective assistance of counsel claim. Factually, Campbell was approached by a police officer in a middle of a night sitting in a stolen car, visibly drinking from an open container of alcohol (vodka bottle).  The critical factual element being that the car was parked in a private church parking lot. Campbell was arrested for POCA (Possession of Open Container of Alcohol), and the ensuing search revealed that the car was stolen and thus was charged with
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