Farris Morris v. Wayne Carpenter
802 F.3d 825
6th Cir.2015Background
- Two murders: Ragland and Erica Hurd, with Ragland murdered by shotgun and Erica stabbed; Morris convicted of two counts of first-degree murder and aggravated rape.
- Penalty-phase death sentence for Hurd, life without parole for Ragland, and a consecutive 25-year aggravated rape term.
- Defense theory centered on cocaine intoxication/mental impairment negating mens rea; prosecution emphasized deliberate planning.
- Defense presented pharmacologist and psychiatrist during guilt phase; post-conviction evidence later suggested bipolar disorder and brain-impairment issues.
- Higher courts denied certiorari; district court granted part of relief on sentencing-phase ineffectiveness but denied guilt-phase relief; appellate court affirming guilt-phase denial and vacating sentencing relief, remanding.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Guilt-phase prejudice from counsel's investigation | Morris's mental impairments were under-investigated | Counsel reasonably relied on experts; investigation was thorough | No reasonable probability of different guilt verdict |
| Sentencing-phase effectiveness of counsel | Mitigation evidence and brain impairment deserved fuller development | Counsel's strategy avoided opening doors to rebuttal; no prejudice | Not unreasonable to conclude no prejudice; Strickland satisfied |
| Martinez/Trevino applicability to defaulted/fully adjudicated claims | Martinez/Trevino allow use of district evidence | Martinez/Trevino do not apply here; no default | Martinez/Trevino do not apply; no procedural default; not controlling |
| Standard of review for AEDPA deference in Strickland claims | State court's Strickland analysis was deficient | State court's application was reasonable; deference applies | State court's decision not contrary to federal law; AEDPA deferential review applied |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance of counsel)
- Martinez v. Ryan, 132 S. Ct. 1309 (S. Ct. 2012) (cause to excuse procedural default for counsel at collateral review)
- Trevino v. Thaler, 133 S. Ct. 1911 (S. Ct. 2013) (expands Martinez on collateral proceedings)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (requires reasonable investigation into defendant's background for mitigation)
- Pinholster v. Arguirre, 131 S. Ct. 1398 (S. Ct. 2011) (limits evidence in federal habeas review to record evidence)
- Harrington v. Richter, 562 U.S. 86 (U.S. 2011) (doubles deferential review under AEDPA when evaluating Strickland)
- Wong v. Belmontes, 558 U.S. 15 (U.S. 2010) (mitigation strategy and risks of opening door to rebuttal)
- Bell v. Cone, 535 U.S. 685 (U.S. 2002) (counsel's strategic choices at mitigation phase)
- Carter v. Bell, 218 F.3d 581 (6th Cir. 2000) (state may rebut mitigation with evidence of defendant's history)
- McGuire v. Warden, Chillicothe Corr. Inst., 738 F.3d 741 (6th Cir. 2013) (reliance on mental-health expert opinions reasonable)
- Goodwin v. Johnson, 632 F.3d 301 (6th Cir. 2011) (mitigation investigation and presentation can support ineffectiveness)