Genesis Hill v. Betty Mitchell
842 F.3d 910
| 6th Cir. | 2016Background
- Genesis Hill was convicted in Ohio of kidnapping and murdering his six‑month‑old daughter and sentenced to death; conviction rested largely on circumstantial evidence and testimony from the victim’s mother, Teresa Dudley.
- Hill filed federal habeas petitions raising, inter alia, a Brady claim that the State suppressed a police report and Dudley’s grand jury testimony favorable to the defense.
- Hill discovered the suppressed police report in December 2007 and Dudley’s grand jury transcript in October 2010 but did not present the Brady claim to the district court until years later.
- The district court found a Brady violation based mainly on the police report, granted a conditional writ, and expanded the record to include the grand jury testimony.
- The Sixth Circuit reversed: it held Hill’s amended Brady claim was time‑barred under AEDPA’s one‑year statute of limitations (and that the district court abused its discretion by treating the late filing as a Rule 60(b)(2) or Rule 15 amendment that could escape the deadline).
- The Sixth Circuit also held, alternatively, that Hill’s Brady claim fails on the merits because the suppressed materials were either ambiguous, of only speculative impeachment value, or cumulative given the strong independent evidence tying Hill to the crime; the court affirmed denial of Hill’s other habeas claims (sufficiency, various ineffective‑assistance claims, proportionality, cumulative error).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hill’s Brady claim (suppressed police report and grand jury testimony) is timely under AEDPA | Hill contends his amended Brady claim relates back to a timely, catch‑all Brady allegation in his original petition or is otherwise actionable after discovery of new evidence | State argues AEDPA’s one‑year limit bars the late Brady claim; district court erred in using Rule 60(b) or allowing relation back under Rule 15 | Held: Time‑barred. District court abused discretion by treating the late submission as Rule 60(b)(2) or allowing relation back under Rule 15; AEDPA deadline controls. |
| Whether the suppressed materials satisfy Brady’s materiality and require relief | Hill argues the police report (suggesting Dudley as a suspect/that she ran and told police to check an alley) and the grand jury testimony (minor inconsistencies) would have meaningfully impeached Dudley and undermined confidence in the verdict | State concedes suppression but contends the items were ambiguous, speculative, or cumulative and would not create a reasonable probability of a different result given other strong evidence | Held: Even on the merits, evidence not material; no reasonable probability of different outcome—Brady claim fails. |
| Whether Hill can overcome state procedural default for his ineffective‑assistance‑of‑trial‑counsel (IATC) claims using Martinez/Trevino exception | Hill invokes Martinez/Trevino to excuse defaults and argues his IATC claims are substantial (failure to obtain mitigation/mental‑health experts; inadequate witness prep) | State argues Ohio procedure permitted meaningful direct review and/or res judicata bars, and Hill cannot show Strickland prejudice or deficient performance | Held: Default stands; Hill cannot show substantial IATC claim or Strickland deficiency/prejudice—claims fail. |
| Whether Ohio’s proportionality review or cumulative error warrant relief | Hill contends state courts did not conduct meaningful proportionality review and cumulative errors denied fair trial | State defends Ohio practice and argues cumulative‑error claims are not recognized under AEDPA | Held: No federal constitutional violation; proportionality review upheld; cumulative‑error claim denied. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s suppression of favorable, material evidence violates due process)
- Strickler v. Greene, 527 U.S. 263 (1999) (elements of a Brady claim: favorable evidence, suppression, materiality/prejudice)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality assessed by whether suppressed evidence could undermine confidence in the verdict; consider cumulative impact)
- Mayle v. Felix, 545 U.S. 644 (2005) (Rule 15(c) relation‑back requires a common core of operative facts; claims cannot relate back merely by arising from same trial)
- Gonzalez v. Crosby, 545 U.S. 524 (2005) (limits on applying Federal Rules in habeas context; Rule 60(b) cannot be used to circumvent AEDPA)
- Smith v. Cain, 565 U.S. 73 (2012) (Brady materiality standard and assessment of star witness impeachment)
- Martinez v. Ryan, 566 U.S. 1 (2012) (narrow exception to procedural default where ineffective assistance at initial collateral review establishes cause)
- Trevino v. Thaler, 569 U.S. 413 (2013) (applies Martinez in certain state procedural contexts where direct appeal is not a meaningful vehicle)