Davis v. Workman, 2012 U.S. App. LEXIS 18241

Davis was convicted in Oklahoma of first-degree murder and rape of Jody Sanford, receiving 100 years for rape and a death sentence for murder.
After state-court appeals and postconviction relief failed, Davis sought federal habeas relief under 28 U.S.C. § 2254.
The district court denied a COA; the Tenth Circuit granted COA on two issues: hospital statements and counsel’s effectiveness regarding impairment evidence.
The court later granted COA on a claim that counsel failed to argue coercion by withholding pain medication, but affirmed denial.
The issues center on the voluntariness of Davis’s hospital statements, alleged coercion, effectiveness of trial counsel, and whether evidentiary or structural errors rendered the trial unfair.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were hospital statements voluntary and knowingly waived?	Davis asserted impairment from morphine undermined waiver.	Waiver was not knowing or voluntary due to medication.	Waiver was knowingly and voluntarily made; statements admissible.
Was trial counsel ineffective for not presenting impairment evidence?	Impairment evidence could have affected trial outcomes.	Counsel acted reasonably; evidence wouldn’t change result.	No reasonable probability of different result; no prejudice.
Did withholding morphine coercively affect statements and render trial unfair?	Coercion by withholding pain meds invalidated statements.	Coercion not established; claims foreclosed by AEDPA standards.	Grant of COA on coercion issue but affirmance on the merits; no prejudice shown.
Does the rebuttal Busby testimony require pretrial disclosure under due process?	Pretrial notice of rebuttal expert was required.	No federal due-process requirement for pretrial disclosure by state.	No federal due-process violation; Busby testimony proper.
Was the evidence sufficient or trial error undue under state law?	Challenged circumstantial evidence and impeachment evidence.	Evidence supported first-degree murder and related claims.	Sufficiency and related claims rejected; cumulative errors not shown.

Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (AEDPA deference and unreasonable application standard explained)
Cullen v. Pinholster, 131 S. Ct. 1388 (U.S. 2011) (deference to state-court factual findings; record-based review)
Renico v. Lett, 130 S. Ct. 1855 (U.S. 2010) (distinguishing wrong applications of federal law from incorrect ones)
Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (two-dimensional Miranda waiver inquiry (voluntariness and comprehension))
Berghuis v. Thompkins, 130 S. Ct. 2250 (U.S. 2010) (Miranda waiver validity standard; knowing voluntary waiver requirements)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective assistance standard; prejudice required)