Eugene Brown v. Kenneth McKee, 460 F. App'x 567

Petitioner Eugene Brown was convicted of first-degree felony murder and felony firearm in Detroit, 1999, and sentenced to life without parole plus two years.
Petitioner challenged ineffective assistance of trial counsel on appeal; sought remand for factual development; Michigan Court of Appeals denied both requests.
Petitioner sought leave to appeal to Michigan Supreme Court, which was denied; federal habeas petition followed under 28 U.S.C. § 2254.
District court denied relief on both ineffective-assistance and due-process grounds but granted a certificate of appealability on ineffective assistance related to competency/insanity issues.
Michigan Court of Appeals affirmed; Petitioner asserted trial counsel failed to investigate competency to stand trial, waiver of Miranda rights, and insanity defense, and presented no defense or witnesses.
Court applied AEDPA deference; affirmed district court, concluding no unreasonable application of Strickland and no prejudice established.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failure to investigate competency/insanity	Brown	Williams	Not unreasonable; relief denied
Prejudice showing under Strickland	Brown	Williams	No substantial likelihood of different outcome

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance)
Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (unreasonableness of application under AEDPA analysis)
Harrington v. Richter, 131 S. Ct. 770 (U.S. 2011) (highly deferential review under §2254(d))
Pinholster v. Ayers, 131 S. Ct. 1388 (U.S. 2011) (AEDPA review limited to state-court record)
Cullen v. Pinholster, 131 S. Ct. 1388 (U.S. 2011) (same AEDPA framework for evidentiary record)
Landrum v. Mitchell, 625 F.3d 905 (6th Cir. 2010) (lower-court interpretations of Supreme Court precedent)