Antonio Senda Wrancher v. Florida Department of Corrections
20-10350
| 11th Cir. | Sep 7, 2021Background:
- Antonio Wrancher was convicted in Florida of first-degree murder for fatally stabbing his ex-girlfriend Cassandra Daley after an argument at a bar; he was sentenced to life.
- At trial the state presented testimony suggesting premeditation: witnesses (Artie Snead Jr., Diane Atkins, Lillian Knight) recounted threats, an ambush-style approach, and multiple stab wounds; the defendant had a knife at the confrontation.
- Pretrial police statements by Snead, Atkins, and Knight differed in material respects from their trial testimony (location, what was heard, and sequence of events).
- Defense counsel impeached Snead with his prior statement but did not impeach Atkins and Knight on those inconsistencies; instead counsel attacked their credibility by other means (bias, criminal history, intoxication/mental issues, on‑stand behavior).
- Wrancher filed a pro se 28 U.S.C. § 2254 petition arguing ineffective assistance under Strickland for failing to impeach Atkins and Knight; the district court denied relief and the Eleventh Circuit granted a COA limited to that issue.
- The Eleventh Circuit affirmed, holding under AEDPA that the state court’s rejection of prejudice under Strickland was not unreasonable given other strong evidence of premeditation.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state post-conviction court unreasonably applied Strickland by rejecting Wrancher’s claim that trial counsel was ineffective for not impeaching Atkins and Knight with prior inconsistent police statements | Counsel’s failure to impeach was deficient and prejudicial; had the jury seen the prior statements, confidence in the guilty verdict on premeditation would be undermined | Counsel made tactical choices to impeach credibility on broader grounds; independent evidence (knife, Snead’s statements, Knight’s police statement, brutal multiple stab wounds) still supported premeditation, so no reasonable probability of a different result | Affirmed: AEDPA deference applies; Wrancher failed to show the state court unreasonably applied Strickland’s prejudice prong; habeas relief denied |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)
- Renico v. Lett, 559 U.S. 766 (2010) (AEDPA deference to state-court rulings)
- Schriro v. Landrigan, 550 U.S. 465 (2007) (federal habeas relief is not warranted unless state-court decision is unreasonable)
- Franks v. GDCP Warden, 975 F.3d 1165 (11th Cir. 2020) (standard of review for habeas denials)
- Yarborough v. Gentry, 540 U.S. 1 (2003) (strategic trial choices entitled to strong presumption of reasonableness)
- Nix v. Whiteside, 475 U.S. 157 (1986) (definition of reasonable probability in Strickland prejudice inquiry)
- Jackson v. State, 180 So. 3d 938 (Fla. 2015) (multiple stab wounds can support an inference of premeditation)
- Miller v. State, 42 So. 3d 204 (Fla. 2010) (nature and manner of wounds relevant to premeditation)
- Preston v. Sec'y, Fla. Dep't of Corr., 785 F.3d 449 (11th Cir. 2015) (recognizing brutal stab wounds as circumstantial evidence of premeditation)
