880 F.3d 857
7th Cir.2018Background
- In 1991 William Little was murdered at a Bloomington, Illinois gas station; eyewitnesses (Martinez, Luna) gave varying descriptions and later identifications; no immediate arrest was made.
- James Snow was later arrested (1999) and implicated by multiple witnesses who testified he made inculpatory statements; Snow maintained an alibi (he and his wife testified they were home).
- Snow was tried (2001), convicted of first‑degree murder, and sentenced to natural life; posttrial state remedies (direct appeal, postconviction petitions, successive petition) were denied at various levels.
- Snow filed a federal habeas petition alleging (1) ineffective assistance of trial counsel for investigative failures and counsel’s alleged alcoholism, and (2) Brady violations for nondisclosure of impeachment/dealings and polygraph materials; the district court denied relief.
- The Seventh Circuit reviewed the denial under AEDPA deference and affirmed, concluding the state courts reasonably applied Strickland and Brady and that some claims were procedurally defaulted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance — failure to investigate and impeach eyewitnesses | Snow: counsel failed to interview officers and call witnesses who would impeach Martinez and Luna | State: counsel reasonably attacked credibility at trial; additional impeachment would be cumulative | Denied — state court reasonably found no prejudice under Strickland |
| Ineffective assistance — counsel’s alcoholism/disbarment (Picl) | Snow: Picl’s alcoholism and later disbarment show deficient performance | State: no specific trial‑time incidents alleged showing deficient or prejudicial performance | Denied — speculative personal problems insufficient under Strickland |
| Brady — deals/leniency given to prosecution witnesses | Snow: prosecution suppressed plea/deal information and inducements that would impeach witnesses | State: documents about sentence departures were public; alleged inducements lacked credibility or materiality | Denied — either not suppressed or not material cumulatively under Brady |
| Brady — coerced/coached testimony (Scheel, others) | Snow: witnesses were coerced/coached; the prosecution failed to disclose these facts | State: Scheel refused to corroborate coercion; other inculpatory evidence remained and impeachment value was limited | Denied — no materiality shown under Brady |
| Brady — polygraph notes and other newly discovered evidence in successive petition | Snow: withheld/unredacted polygraph notes would impeach Martinez/Scheel | State: polygraph inadmissible under Illinois law and notes were vague/repetitive; Illinois court found lack of prejudice | Denied — either procedurally defaulted or not material when considered cumulatively |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑part ineffective assistance standard: deficient performance and prejudice)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution suppression of material favorable evidence violates due process)
- Kyles v. Whitley, 514 U.S. 419 (1995) (Brady materiality assessed cumulatively)
- Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference standard; petitioner must overcome wide range for unreasonable application)
- Cullen v. Pinholster, 563 U.S. 170 (2011) (AEDPA’s deferential standard is difficult to meet)
- Banks v. Dretke, 540 U.S. 668 (2004) (cause and prejudice in procedural default parallel Brady analysis)
- O’Sullivan v. Boerckel, 526 U.S. 838 (1999) (state remedies exhaustion requires one complete round of appellate review)
- United States v. Bagley, 473 U.S. 667 (1985) (no distinction for Brady between exculpatory and impeachment evidence)
- Giglio v. United States, 405 U.S. 150 (1972) (impeachment evidence related to witness deals must be disclosed)
- Coleman v. Thompson, 501 U.S. 722 (1991) (procedural default doctrine and cause/prejudice framework)