Erik Courtney Lehto v. State of Tennessee

The Petitioner, Erik Courtney Lehto, appeals the Knox County Criminal Court’s denial of
post-conviction relief from his convictions for two counts of rape of a child, one count of
aggravated sexual battery, and one count of solicitation of rape of a child. The Petitioner
alleges that he received ineffective assistance of counsel based on four asserted grounds:
(1) trial counsel failed to ask key credibility-related questions during the Petitioner’s direct
examination regarding household tension between him and the minor victim; (2) trial
counsel failed to cross-examine the minor victim about other men in her environment who,
according to the Petitioner, could have provided alternative explanations or suspects; (3)
trial counsel erred by stipulating to evidence describing the Petitioner’s arrest near the U.S.-
Mexico border, which suggested flight and implied consciousness of guilt; and (4) the
cumulative effect of these alleged deficiencies deprived him of a fair trial.1 Upon our
review, we affirm the judgment of the post-conviction court.