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Antonio Senda Wrancher v. Florida Department of Corrections
20-10350
| 11th Cir. | Sep 7, 2021
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Background:

  • 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)
Read the full case

Case Details

Case Name: Antonio Senda Wrancher v. Florida Department of Corrections
Court Name: Court of Appeals for the Eleventh Circuit
Date Published: Sep 7, 2021
Docket Number: 20-10350
Court Abbreviation: 11th Cir.