Davel Chinn v. Warden, Chillicothe Corr. Inst., 24 F.4th 1096

In January 1989 Brian Jones was fatally shot during a carjacking in Dayton; co-participant Marvin Washington identified the shooter as “Tony,” later identified as Davel Chinn.
Police developed a composite sketch; Shirley Cox recognized a man who visited her husband’s law office and reported him; photo array and a lineup produced identifications by Washington, Ward, and Cox. Chinn was arrested, tried, convicted of aggravated murder and related offenses, and sentenced to death.
After conviction, defense counsel obtained Washington’s juvenile records disclosing severe intellectual impairments (reported IQ in the 40s–50s) and other cognitive limitations; those records were not disclosed to defense before trial.
Chinn raised a Brady claim (suppression of impeachment/exculpatory material), an evidentiary claim (admission of Cox’s testimony that mentioned a law office), and a sentencing/mitigation claim; the Ohio courts held an evidentiary hearing but rejected relief; the federal district court denied § 2254 relief and granted COA on the Brady and evidentiary issues (and a third sentencing issue Chinn later waived on appeal).
The Sixth Circuit reviewed under AEDPA deference and affirmed denial of habeas relief: it held the state court reasonably found the juvenile records immaterial under Brady and that the admission of Cox’s testimony was harmless error.

Issue	Chinn's Argument	State/Warden's Argument	Held
Brady suppression of Washington’s juvenile records (impeachment of ID)	Withheld records showing severe intellectual disability would have impeached Washington’s identification and created a reasonable probability of a different outcome	Records were cumulative to impeachment presented at trial; other evidence corroborated Washington and supported reliability of his ID; no prejudice	Denied — state court reasonably applied Brady/AEDPA; no reasonable probability of different outcome
Admission of Cox’s testimony referencing a law office visit	Mention that the encounter occurred at a law office unfairly suggested Chinn sought counsel and was prejudicial and irrelevant	Testimony was relevant to Cox’s later identification from the composite; any error was harmless given centrality of Washington’s testimony	Denied — admission harmless under AEDPA; no actual prejudice
Sentencing/mitigation (jury recommendation validity)	(Raised below) trial errors deprived Chinn of right to present mitigating evidence and valid jury recommendation	State prevailed at lower courts	Waived on appeal to Sixth Circuit; not considered further

Brady v. Maryland, 373 U.S. 83 (1963) (establishes prosecution’s duty to disclose favorable exculpatory and impeachment evidence)
Strickler v. Greene, 527 U.S. 263 (1999) (sets three components of a Brady claim: favorable, suppressed, material/prejudicial)
Kyles v. Whitley, 514 U.S. 419 (1995) (materiality: reasonable probability of a different result undermining confidence in outcome)
United States v. Bagley, 473 U.S. 667 (1985) (Brady materiality standard explained as undermining confidence in outcome)
Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA standard for federal habeas review of state-court decisions)
Harrington v. Richter, 562 U.S. 86 (2011) (emphasizes AEDPA deference; state-court decisions must be unreasonable, not merely incorrect)
Wearry v. Cain, 577 U.S. 385 (2016) (Brady analysis where withheld evidence undermined key witness veracity; distinguishable on facts)
White v. Woodall, 572 U.S. 415 (2014) (clarifies limits on extending Supreme Court precedent for AEDPA purposes)
Davis v. Ayala, 576 U.S. 257 (2015) (harmless-error standard in habeas context; requires lack of actual prejudice)