Goins v. Warden, Perry Correctional Institution, 576 F. App'x 167

Appellant Edmund Goins, an inmate, challenged his life ABWIK sentence as ineffective assistance of counsel for not presenting mental health evidence to negate mens rea.
SC PCR court found prejudice and granted relief on all three counts, suggesting mental health history could undermine ABWIK mens rea.
SC Court of Appeals reversed PCR relief, stating diminished capacity defense is not recognized in South Carolina and prejudice was not shown.
Federal district court denied habeas relief and COA; this court granted COA on the effectiveness issue.
This court reviews AEDPA standards de novo on legal questions and deferentially on state court factual determinations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the SC Court of Appeals’ application of diminished capacity law an unreasonable application of federal law?	Goins contends the court misapplied Strickland by treating mental health evidence as a non-cognizable diminished capacity defense.	Goins I correctly held that diminished capacity defense is not recognized in South Carolina state law, so prejudice could not attach.	No unreasonable application; affirmed.
Did trial counsel’s failure to introduce mental health evidence prejudice the outcome under Strickland?	Goins asserts prejudice from failure to present mental health evidence would undermine trial confidence.	Evidence would have been inadmissible; prejudice absent if evidence cannot be admitted.	Not prejudicial; affirmed.
Were any admissibility-fact determinations by the SC court unreasonable under 2254(d)(2)?	Goins argues the appellate court erred in assuming inadmissibility of evidence and its impact on mens rea.	No unreasonable factual determinations showed; findings supported by record.	No unreasonable determinations; affirmed.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (standard for ineffective assistance of counsel; prejudice required)
Gill v. State, 552 S.E.2d 26 (S.C. 2001) (diminished capacity not recognized in South Carolina)
State v. Santiago, 634 S.E.2d 23 (S.C. Ct. App. 2006) (diminished capacity defense not recognized in South Carolina)
Porter v. McCollum, 558 U.S. 30 (U.S. 2009) (Strickland prejudice framework and deference in review)
Garza v. Stephens, 738 F.3d 669 (5th Cir. 2013) (merits of failing to present meritless evidence cannot prejudice)
Hoots v. Allsbrook, 785 F.2d 1214 (4th Cir. 1985) (admissibility and strategic decisions not amounting to ineffective assistance)
Beaver v. Thompson, 93 F.3d 1186 (4th Cir. 1996) (failure to proffer favorable post-conviction evidence fatal to claim)
Bassette v. Thompson, 915 F.2d 932 (4th Cir. 1990) (need for proffer of what evidence would show to prove prejudice)
Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (unreasonable application standard for federal law under AEDPA)
Harrington v. Richter, 131 S. Ct. 770 (U.S. 2011) (AEDPA deference and fairminded disagreement standard)
Woodford v. Visciotti, 537 U.S. 19 (U.S. 2002) (AEDPA deference and state court review)
Wong v. Belmontes, 558 U.S. 15 (U.S. 2009) (reasonable probability and evidence affecting guilt evaluation)
Merzbacher v. Shearin, 706 F.3d 356 (4th Cir. 2013) (objectively unreasonable factual determinations under §2254(d)(2))