Guzman v. Secretary, Department of Corrections
2011 U.S. App. LEXIS 24465
| 11th Cir. | 2011Background
- Guzman was sentenced to death for murder in Florida; direct appeal upheld convictions but not all aggravators.
- Postconviction petition (Rule 3.850) raised Brady and Giglio claims about Cronin, and a $500 reward payment to Cronin; state court held hearings and denied relief.
- Florida Supreme Court adjudicated the Giglio claim on the merits, remanding for proper Giglio materiality analysis; it ultimately denied relief for Giglio and Brady.
- District Court granted Guzman habeas relief based on an unreasonable application of Giglio materiality and ordered a new trial; it declined to decide Brady.
- State court proceedings, and the AEDPA review framework, were central to whether the Florida court’s decision was “contrary to” or an unreasonable application of clearly established federal law.
- The Eleventh Circuit affirmed the habeas relief on the Giglio claim, holding the Florida court’s materiality determination was an objectively unreasonable application of Supreme Court precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Giglio materiality was applied reasonably? | Guzman contends the Florida Supreme Court misapplied Giglio materiality. | The state court correctly applied Giglio, finding the reward evidence immaterial. | Unreasonable application; Guzman prevails on Giglio. |
| Did undisclosed $500 reward and perjury affect the verdict? | The reward and perjury were significant and could have influenced credibility. | The record shows substantial corroboration; impact was immaterial. | Yes; potential effect on verdict; new trial warranted. |
| AEDPA review standard applied correctly? | State court’s ruling was an unreasonable application of clearly established law. | State court’s reasoning fell within AEDPA deference. | Unreasonable application; relief granted. |
Key Cases Cited
- Napue v. Illinois, 360 U.S. 264 (1959) (false evidence or failure to correct false testimony violates due process)
- Brady v. Maryland, 373 U.S. 83 (1963) (favorable evidence disclosure required when material to guilt or punishment)
- Giglio v. United States, 405 U.S. 150 (1972) (materiality of impeachment evidence standard for witness credibility)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality Depends on whether undisclosed evidence undermines confidence in verdict)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (standards for § 2254(d)(1) review; fairminded disagreement)