Humphrey v. Lewis
291 Ga. 202
| Ga. | 2012Background
- Lewis was convicted in 1998 of malice murder, burglary, and related offenses and sentenced to death.
- Post-appeal, Lewis’ habeas petition resulted in relief at first, with the habeas court vacating all convictions on several grounds, which this Court reversed on remand.
- The underlying facts show domestic violence between Lewis and Cheryl Lewis, culminating in her death with 42 injuries and severed carotid/jugular arteries; DNA from Lewis’ clothing matched Cheryl Lewis’ profile.
- Investigative notes and a GBI shoe-print report were allegedly suppressed, prompting a Brady claim analyzed for materiality and prejudice.
- The record discusses the Silinzy notes (roommate interview) and a GBI report denying a bloody shoe print connection, evaluated for their collective materiality.
- The Court ultimately reinstates Lewis’ convictions, reversing the habeas court’s relief and addressing procedural defaults and evidentiary theories.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady claim procedural default and materiality | Lewis | Lewis | Brady default affirmed; no prejudice; collective evidence not material |
| Effect of Silinzy notes on materiality | Lewis | Lewis | No material impact on outcome; no reasonable probability of different result |
| GBI shoe print report suppression | Lewis | Lewis | Collective evidence insufficient to show prejudice; no different trial result |
| Voluntary manslaughter jury instruction | Lewis | Lewis | Appellate counsel ineffective at most; no reasonable probability of different outcome |
| Prosecutorial misconduct and trial court error | Lewis | Lewis | No reversible error; default preserved; no prejudice shown |
Key Cases Cited
- Kyles v. Whitley, 514 U.S. 419 (Supreme Court 1995) (materiality must be evaluated collectively for Brady violations)
- Waldrip v. Head, 279 Ga. 826 (Ga. 2005) (procedural-default doctrine and cause/prejudice analysis in habeas)
- Todd v. Turpin, 268 Ga. 820 (Ga. 1997) (procedural default overcoming standards for habeas claims)
- Reynolds v. State, 271 Ga. 174 (Ga. 1999) (provocation and voluntary manslaughter standards in Georgia)
- Gissendaner v. State, 272 Ga. 704 (Ga. 2000) (standards for improper comments and impact on sentencing)
- Lloyd v. State, 280 Ga. 187 (Ga. 2006) (principles on ineffective assistance and finality of counsel)