David Lee Roberts v. Commissioner, Alabama Department of Corrections
677 F.3d 1086
11th Cir.2012Background
- Roberts, an Alabama prisoner, was convicted of two counts of capital murder in 1992 and initially sentenced to death after a bench sentencing on remand.
- The jury at the guilt phase recommended life without parole, but the trial judge later imposed death after a separate penalty-phase hearing.
- Roberts' offense involved robbery, murder of Annetra Jones, and arson at Satterfield’s house, with evidence of concealment and flight.
- Roberts gave multiple statements; in his final statement he claimed an older person coerced him to burn the house and shoot Jones.
- On direct appeal, his conviction was affirmed but the death sentence reversed and remanded due to exclusion of some sentencing evidence; on remand, the judge conducted another, non-jury sentencing hearing, again imposing death.
- Roberts pursued Rule 32 post-conviction relief, advancing three ineffective-assistance-of-counsel claims, including failure to investigate and present an insanity defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for insanity defense strategy | Roberts: Odum failed to investigate/present insanity defense | State: claim procedurally defaulted | No procedural default; but no prejudice shown under Strickland |
| Failure to instruct on felony murder as a lesser-included offense | Roberts: evidence supports felony murder instruction | Beck c. Alabama not violated given evidence of intent | Not an unreasonable application of Beck; no instruction required based on record |
| Resentencing before a jury vs. judge-only hearing | Roberts: jury must hear aggravating/mitigating evidence | Harris and Spaziano permit judge-only resentencing | No unreasonable application; Harris/Harris-era rule controls; jury not required |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. (1984)) (establishes prejudice and performance standards for ineffective assistance)
- Beck v. Alabama, 447 U.S. 625 (U.S. (1980)) (rights regarding lesser-included offenses in capital cases)
- Schad v. Arizona, 501 U.S. 624 (U.S. (1991)) (limits Beck applicability when noncapital option exists)
- Harris v. Alabama, 513 U.S. 504 (U.S. (1995)) (no constitutional right to jury sentencing; advisory verdict weight not constitutionally required)
- Spaziano v. Florida, 468 U.S. 447 (U.S. (1984)) (no constitutional right to jury sentencing in capital cases)
- Weeks v. Jones, 26 F.3d 1030 (11th Cir. (1994)) (prejudice requires showing ineffective insanity defense would alter outcome)
- Rompilla v. Beard, 545 U.S. 374 (U.S. (2005)) (prejudice analysis in Strickland review may apply AEDPA deferment limits)
- Williams v. Allen, 598 F.3d 778 (11th Cir. 2010) (Alabama insanity standard; clear and convincing evidence burden)
- Ex parte Roberts, 735 So.2d 1270 (Ala.1999) (Alabama Supreme Court on Rule 32 proceedings)
- Roberts v. State, 735 So.2d 1244 (Ala.Crim.App.1997) (direct appeal/Remand for sentencing context)