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Okonkwo v. State

Trial counsel was not ineffective for failing to request a jury instruction on the mistake of fact defense in defendant’s trial for forgery of money. Forgery of money requires the State to prove intent to defraud or harm another, which also requires the State to show the defendant knew the bills were forged. Proof of the culpable mental state necessarily proves lack of mistake regarding authenticity of the bills, so trial counsel was not objectively unreasonable in failing to request the instruction.
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