Michael Douglas v. State of Tennessee

The Appellant, Michael Douglas, appeals a 1 s of right from the judgment of the Shelby County
Criminal Court denying his petition for post-conviction relief. Douglas was convicted in 2000 of
attempted second degree murder and especially aggravated robbery. On appeal, Douglas contends that he was denied the effective assistance of counsel due to trial counsel’s (1) failure to seek suppression of a photo array because the photograph used was obtained following an unlawful arrest and (2) failure to adequately cross-examine a witness as to whether an agreement existed between the witness and the State. After review of the issues presented, the judgment is affirmed.