Billy Crutsinger v. William Stephens, Director, 576 F. App'x 422

Crutsinger was convicted of capital murder and sentenced to death in Texas after a jury trial; direct appeal and state habeas proceedings followed prior to federal review.
The Fifth Circuit granted rehearing en banc, withdrew the prior opinion, and substituted a ruling denying Crutsinger a certificate of appealability (COA).
Crutsinger sought federal habeas relief; the district court found his ineffective-assistance-of-counsel (IAC) claim was procedurally barred from review, but addressed it de novo on the merits.
The district court found trial counsel’s social-history investigation, including use of a mitigation specialist, thorough, and that counsel’s strategic decisions were reasonable and not prejudicial.
Crutsinger argued the timing of the investigation prevented presenting evidence of brain impairments and alcohol addiction; the district court rejected this as insufficient to show deficiency or prejudice.
Crutsinger sought investigative funding under 18 U.S.C. § 3599; the district court denied funding; the court of appeals later reviewed the funding denial for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether IAC claim is debatable on the merits	Crutsinger asserts counsel failed to timely investigate social history affecting mitigation.	Crutsinger's IAC claim was adequately investigated; no prejudice shown.	No debatable conclusion; COA denied.
Whether district court abused its discretion in denying § 3599 funding	Funding was necessary to develop an IAC claim after Martinez and related standards.	Funding properly denied; claim procedurally barred or not substantial.	No abuse of discretion; funding denied.
Whether Martinez requires pre-petition funding or excusing default	Martinez requires more expansive relief for funding post-Martinez change in law.	Martinez does not litigate pre-petition funding or overcome procedural default without substantial IAC merit.	District court did not err; remand unnecessary; Martinez does not compel funding.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-pronged IAC standard: deficient performance and prejudice)
Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (counsel's performance judged with deference and hindsight discounting)
Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (thorough investigation and strategy; not every mitigating line must be explored)
Moore v. Quarterman, 534 F.3d 454 (5th Cir. 2008) (COA standard for capital cases; reasonable jurists may debate)
Martinez v. Ryan, 132 S. Ct. 1309 (U.S. 2012) (procedural-default exception for ineffective-assistance claims in initial-review collateral proceedings)
Trevino v. Thaler, 133 S. Ct. 1911 (U.S. 2013) (extension of Martinez to certain Texas prisoners)
Miller–El v. Cockrell, 537 U.S. 322 (U.S. 2003) (COA standard for habeas corpus claims)
Stone v. Powell, 428 U.S. 465 (U.S. 1976) (federal habeas review limited by strong evidence of state-court processes)
Woodward v. Epps, 580 F.3d 318 (5th Cir. 2009) (review of § 3599 funding decisions for abuse of discretion)
Magouirk v. Phillips, 144 F.3d 348 (5th Cir. 1998) (procedural default and discretionary review standards)