Brown v. State, 2012 Miss. LEXIS 155

Brown was convicted of capital murder for killing a store clerk during an armed robbery in 1992 and received a death sentence by lethal injection.
This Court previously affirmed the conviction and sentence on direct appeal in 1996.
Brown later sought post-conviction relief alleging ineffective assistance of trial counsel for not obtaining an independent psychiatric evaluation for mitigation.
A special judge denied the post-conviction relief petition, and Brown appealed.
On appeal, the sole issue before the Court was whether discovery was improperly denied and whether counsel’s failure to secure mitigating expert evidence was deficient.
The Court affirmed the denial of post-conviction relief, holding trial counsel’s decisions were not deficient and the discovery denial was not an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brown was entitled to discovery under Rule 22(c)(4)	Brown argues entitlement to complete trial, investigative, and prosecutorial files	The majority held Rule 22(c)(4) governs preliminary proceedings; discovery was governed by 99-39-15	Discovery denied; no abuse of discretion
Whether trial counsel’s failure to obtain a psychological mitigation report was deficient	Brown contends failure to seek mitigation evidence harmed sentencing	Counsel's strategic decision not to obtain or present the report was reasonable	Not deficient; no prejudice established

Doss v. State, 19 So.3d 690 (Miss. 2009) (standard for reviewing factual findings; discovery rulings reviewed for abuse of discretion)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel; deficiency and prejudice)
Roland v. State, 666 So.2d 747 (Miss. 1995) (discovery and good cause in post-conviction; abuse of discretion standard)
Russell v. State, 819 So.2d 1177 (Miss. 2001) (discovery; good cause; pre-hearing framework)