Hunt v. Commissioner, Alabama Dept. of Corrections
666 F.3d 708
11th Cir.2012Background
- Hunt, a death-row inmate in Alabama, was convicted of three counts of capital murder and sentenced to death in 1990.
- Trial evidence showed Lane's death following a night of pursuit, arson of Lane's house, and various statements by Hunt indicating hostility toward Lane.
- Hunt argued ineffective assistance of counsel under Strickland and was denied post-conviction relief in Alabama courts.
- Rule 32 petition proceedings were lengthy and culminated in an evidentiary hearing that produced little favorable testimony for Hunt.
- Alabama Supreme Court and federal district court denied relief; AEDPA standard governs review on habeas corpus petitions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prejudice proof requirement for IAC claims | Hunt argues prejudice requires extrinsic evidence per Wiggins/Williams | Alabama courts did not mandatorily require extrinsic prejudice proof | No improper extrinsic-prejudice prerequisite applied |
| Cross-examination of Sanders and credibility | Cross-examination failed to expose bias; insufficient impeachment | Counsel reasonably pursued bias via motives and record; no deficiency | Counsel's cross-examination not deficient; no prejudice shown |
| Intoxication and lesser-included offenses instructions | Counsel should have requested intoxication and manslaughter instructions | Defense strategy favored innocence/other theory; intoxication defense unwarranted | No deficient performance; no reasonable probability of different outcome |
| Felony-murder instruction and exhaustion | Failure to request felony-murder instruction could be ineffective assistance | Claim not exhausted; procedurally defaulted; not ripe for merits review | Claim procedurally defaulted and not addressed on merits |
| Cumulative error doctrine applicability | Cumulative errors warrant reversal | Cumulative errors not shown to injuriously affect substantial rights | No reversal on cumulative-groundal basis |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance of counsel)
- Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (defines 'clearly established Federal law' for AEDPA review)
- Harrington v. Richter, 563 U.S. _, 131 S. Ct. 770 (U.S. 2011) (tests deferential review under AEDPA post-Strickland)
- Knowles v. Mirzayance, 556 U.S. 111 (U.S. 2009) (explains 'doubly' deferential review under AEDPA and Strickland)
- Dill v. Allen, 488 F.3d 1344 (11th Cir. 2007) (nonfrivolous defenses not required; strategic choices favored)