ABDUR'RAHMAN v. Colson, 2011 U.S. App. LEXIS 17010

Abdur'Rahman was convicted in 1987 of first-degree murder, assault with intent to commit first-degree murder, and armed robbery, and sentenced to death plus two consecutive life terms.
At sentencing, he claimed a quasi-religious group SEGM influenced the crime; leaders Beard and Boyd allegedly supplied weapons and aided escape.
On direct and state post-conviction review, the Tennessee courts affirmed the convictions and sentences; federal habeas petitions followed after 1996.
Abdur'Rahman alleged Brady violations: (i) Miller's pre-trial statements about SEGM’s influence, and (ii) Detective Garafola's report describing head-banging and related conduct at arrest.
The district court rejected the Brady claims as non-material; the Sixth Circuit granted a COA to consider two Brady subclaims in tandem with the cumulative-error framework.
The court ultimately affirmed denial of relief, holding the withheld evidence was not material to sentencing or death-penalty fairness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller's pre-trial statements were material to sentencing as Brady evidence	Abdur'Rahman contends withholding Miller's pre-trial SEGM statements violated Brady and could affect life/death verdict.	The district court held the statements were knowable by defense and thus not Brady material.	No Brady violation; withheld statements were known to defense and not material to sentence.
Whether Garafola's redacted head-banging report was material to sentencing	Garafola's report showing mental distress could mitigate and undermine death sentence.	Redacted portion lacked reliance to mental illness and would not change outcome; cumulative impact analyzed.	Not material; cumulative impact did not alter probability of different death vs life verdict.
Whether the Brady claims can be considered cumulatively with other claims	Brady, together with prosecutorial misconduct and Strickland claims, require holistic review to assess prejudice.	Cumulative claims were not properly preserved or certified; separate treatment warranted.	Cumulative-Brady analysis limited by procedural posture; overall prejudice not shown to mandate relief.
Whether hybrid Brady/Strickland claim merits relief	Brady violations combined with ineffective assistance could yield relief for sentencing.	Procedural default forecloses hybrid review; COA limitations apply.	Procedural default prevents full review; no relief on hybrid claim.

Bell v. Bell, 512 F.3d 223 (6th Cir. 2008) (Brady standard and materiality framework for impeachment/exculpatory evidence)
Kyles v. Whitley, 514 U.S. 419 (S. Ct. 1995) (collective evaluation of suppressed evidence for materiality)
Apanovitch v. Houk, 466 F.3d 460 (6th Cir. 2006) (Brady applies to evidence known to defense; not a disclosure duty if defense knows facts)
Byrd v. Collins, 209 F.3d 486 (6th Cir. 2000) (impeachment value does not require disclosure where defense can impeach witness)
Cone v. Bell, 556 U.S. 180 (S. Ct. 2009) (materiality assessed in light of overall record and reliability of evidence)
Doan v. Carter, 548 F.3d 449 (6th Cir. 2008) (cumulative Brady analysis requires considering only suppressed, favorable evidence)
Rompilla v. Beard, 545 U.S. 374 (S. Ct. 2005) (mitigating evidence related to mental health can be prejudicial in capital cases)
Porter v. McCollum, 130 S. Ct. 447 (2009) (prejudice from failure to present mitigating evidence in capital sentencing)
State v. Jones, 789 S.W.2d 545 (Tenn. 1990) (capital sentencing framework; unanimous jury required for death sentence)
Abdur'Rahman v. Bell, 226 F.3d 696 (6th Cir. 2000) (ineffective assistance; post-conviction relief related to penalty-phase)