Brown v. Vannoy, 2:20-cv-02933-SM

Ricky D. Brown was convicted of second-degree murder in Louisiana (Feb. 29, 2012) and sentenced to life without parole; state appellate and supreme courts denied relief.
Victim Edith West was found dead in a bayou, hands bound and a cinder block tied to her neck; cause of death likely asphyxia.
Key evidence at trial consisted of confessions/admissions Brown made to two witnesses (Mike Brown and Vickie Brown) describing his participation with co-defendant Mike Burnett in binding and throwing the victim into the water.
No physical evidence directly tied Brown to the murder; defense attacked witness credibility.
Brown raised three claims in state and federal collateral proceedings: (1) trial counsel denied him the right to testify, (2) insufficient evidence, and (3) actual innocence. Counsel testified she advised him not to testify but left the decision to him; the state court found no prohibition.
The magistrate judge applied AEDPA deferential review and recommended dismissing Brown’s § 2254 petition with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance — counsel refused to let Brown testify	Brown: trial counsel refused/forbade him from testifying, violating his right to testify and constituting ineffective assistance	State: counsel testified she recommended against testifying but did not forbid him; decision was Brown's; strategic advice was reasonable	Denied — state court finding that counsel did not forbid testimony was reasonable; no Strickland relief under AEDPA
Ineffective assistance — counsel’s advice against testifying was deficient	Brown: even advice not to testify was unreasonable and prejudicial	State: choice not to testify was a judgment call/strategy; counsel’s recommendation was reasonable given admissions and cross-examination risk	Denied — strategic decision within wide range of reasonable assistance; no prejudice shown
Insufficient evidence to support conviction	Brown: conviction rests on incredible, non‑eyewitness testimony and lacks physical links	State: confessions to two witnesses were direct evidence; jurors weighed credibility; evidence viewed in prosecution’s favor was sufficient	Denied — under Jackson standard, rational juror could convict; state-court decision not objectively unreasonable
Freestanding actual innocence	Brown: asserts he is actually innocent	State: Fifth Circuit does not recognize freestanding actual-innocence claims on federal habeas	Denied — freestanding claim not cognizable in this circuit

Strickland v. Washington, 466 U.S. 668 (establishes two-part ineffective-assistance test)
Jackson v. Virginia, 443 U.S. 307 (sets standard for sufficiency of the evidence)
Bell v. Cone, 535 U.S. 685 (explains AEDPA’s role in limiting federal habeas review)
Harrington v. Richter, 562 U.S. 86 (describes deference when Strickland and AEDPA overlap)
White v. Woodall, 572 U.S. 415 (limits habeas relief when state courts do not clearly err in applying precedent)
Renico v. Lett, 559 U.S. 766 (emphasizes that federal courts must not second-guess reasonable state-court decisions)
Cavazos v. Smith, 565 U.S. 1 (reinforces deference in Jackson claims)
Rock v. Arkansas, 483 U.S. 44 (recognizes defendant’s right to testify)
Wooten v. Thaler, 598 F.3d 215 (5th Cir.) (explains ‘contrary to’ standard under § 2254(d)(1))
Underwood v. Clark, 939 F.2d 473 (7th Cir.) (discusses need for substantiation when a defendant claims counsel barred testimony)