Doyle Lee Hamm v. Commissioner, Alabama Department of Corrections, 620 F. App'x 752

Hamm was convicted of robbery-murder in 1987 and sentenced to death by an Alabama court.
Two Tennessee convictions were used as aggravating factors in Hamm’s capital sentencing.
Hamm challenged the Tennessee convictions as unconstitutionally obtained and sought §2254 relief.
The district court and state courts rejected Hamm’s claims, including ineffective-assistance and Brady-related issues.
The district court held Coss bars merits review of the expired Tennessee convictions; Martinez did not apply to Brady or Rule 32 claims.
The Eleventh Circuit affirmed, addressing jurisdiction, procedural default, and Strickland-based mitigation claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May Hamm challenge the Tennessee convictions as invalid under Coss?	Hamm argues Coss does not bar merits review in capital cases.	State contends Coss bars review of expired convictions used to enhance the sentence.	Coss bars merits review; no exceptions apply.
Were Hamm's trial/Rule 32 mitigation practices deficient under Strickland?	Hamm asserts counsel failed to uncover/introduce extensive mitigation evidence.	State argues counsel’s investigation and presentation were reasonable; no prejudice shown.	No deficient performance or prejudice; mitigation claims denied.
Did the Roden Brady claim have procedural compliance and merit?	Roden records were seized late; Brady material could impeach the witness; Martinez should apply.	Default prevents review; even if reached, evidence not material.	Claim procedurally defaulted; merits denied.
Does Martinez provide a broad equitable remedy for defaulted claims?	Martinez should excuse default for initial-review collateral issues and permit merits review.	Martinez narrow, limited to ineffective-trial-counsel claims; does not extend to this default.	Martinez does not apply; default remains.

Lackawanna County Dist. Attorney v. Coss, 532 U.S. 394 (U.S. 2001) (cannot challenge expired convictions used to enhance a sentence under §2254)
Johnson v. Mississippi, 486 U.S. 578 (U.S. 1988) (death sentence based on aggravated circumstances requires reliability)
Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (counsel must investigate prior convictions when the state will rely on them)
Martinez v. Ryan, 132 S. Ct. 1309 (S. Ct. 2012) (limited exception allowing initial-review collateral errors to establish cause for trial-counsel claims)
McCleskey v. Zant, 499 U.S. 467 (U.S. 1991) (narrow miscarriage-of-justice standards in habeas review)
Custis v. United States, 511 U.S. 485 (U.S. 1994) (limits on collateral attack; ties to Gideon framework)
Daniels v. United States, 532 U.S. 374 (U.S. 2001) (further limits on collateral relief; clarifies non-applicability to certain claims)
Treviño v. Thaler, 133 S. Ct. 1911 (S. Ct. 2013) (discusses Martinez applicability in various collateral contexts)