Damon Goodloe v. Christine Brannon, 4f4th445

Goodloe was convicted of first-degree murder for the fatal shooting of Pierre Jones after a late-night shooting; Jones identified “Damon” and described a black hoodie at the scene.
Minutes after the shooting, officers found Goodloe a few blocks away wearing a black hoodie under a jacket; he initially gave a false name and was brought back to the ambulance where Jones made show-up identifications (“That’s him, he’s the one that shot me” and “Yeah, that’s the guy”).
Trial evidence also included gunshot residue on Goodloe’s hands and reluctant eyewitness testimony from Michelle Lovett who had earlier signed a recanting affidavit after threats.
Goodloe was convicted, moved for a new trial based on ineffective assistance, lost in state appellate and post-conviction review, then filed a 28 U.S.C. § 2254 habeas petition; the district court denied relief.
The Seventh Circuit granted a certificate of appealability limited to (1) whether admission of Jones’s show-up statements violated the Confrontation Clause and (2) whether counsel was ineffective for failing to investigate/call three witnesses who might explain Goodloe’s presence.

Issue	Goodloe's Argument	State's Argument	Held
Whether Jones’s show-up statements were testimonial (Confrontation Clause)	The ambulance show-up identifications were testimonial and inadmissible because there was no ongoing emergency when Officer brought Goodloe to the ambulance for ID.	The statements were nontestimonial under Davis because they were made to meet an ongoing emergency—officers were still resolving who the shooter was.	Court held the state court reasonably applied Crawford/Davis: statements were nontestimonial because an ongoing emergency existed; no habeas relief.
Whether trial counsel was ineffective for not investigating/calling three witnesses (Lee, Young, McKinley)	Counsel’s failure deprived Goodloe of potentially exculpatory testimony that would explain his presence and undermine the prosecution’s case.	Counsel’s decisions were reasonable; the witnesses offered no strong alibi or helpful testimony and might have harmed the defense.	Court held state court reasonably applied Strickland: no prejudice shown given strong identification, forensic evidence, and reluctant eyewitness; no habeas relief.

Crawford v. Washington, 541 U.S. 36 (establishes that testimonial statements violate the Confrontation Clause absent prior cross-examination or unavailability exception)
Davis v. Washington, 547 U.S. 813 (announces the ongoing-emergency test to distinguish testimonial from nontestimonial statements)
Strickland v. Washington, 466 U.S. 668 (sets the two-prong standard for ineffective assistance: deficient performance and prejudice)
Harrington v. Richter, 562 U.S. 86 (explains § 2254(d)’s deferential standard and "fairminded jurists" test for unreasonable application)
McGirt v. Oklahoma, 140 S. Ct. 2452 (clarifies when a state-court opinion that is interwoven with federal law allows federal review despite procedural rulings)