From the L.A. Times:
In August 2001, a federal appeals court ruled that Burdine was entitled to a new trial because there was “fundamental unfairness in [his] capital murder trial created by the consistent unconsciousness of his counsel,” Judge Fortunato P. Benavides wrote, noting that Joe Frank Cannon was “repeatedly asleep” when witnesses testified against his client. “Unconscious counsel equates to no counsel at all.”
…At a 1995 hearing, Cannon denied he had slept during Burdine’s 1984 trial. Rather, he said, he was concentrating with his eyes closed.
Yeah, that never worked in school either…