Jarnard M. Williams v. Warden
714 F. App'x 958
| 11th Cir. | 2017Background
- October 2007: A shooting left Wymberly Baker dead and Donald Robinson wounded; eyewitness Isaac Fitzgerald later identified Jarnard Williams in photo lineups and at trial as one of the shooters.
- At trial Fitzgerald was an important ID witness; he initially expressed uncertainty but ultimately identified Williams; defense attempted impeachment about possible benefits for Fitzgerald.
- Prosecutor Melanie Higgins met Fitzgerald pretrial, told him she would tell the prosecutor handling his separate case (Ann Elmore) that he was helpful if he testified; no formal plea offer was made before trial; afterwards Elmore did offer and Fitzgerald accepted a plea.
- Williams challenged his conviction through state appeal (claims of ineffective assistance rejected) and state habeas (Brady/impeachment evidence and counsel errors). The state habeas court denied relief, finding no deal and no materiality.
- In federal habeas proceedings the magistrate judge and district court held Higgins had an obligation under Brady to disclose the promise to communicate favorable testimony to Elmore and that the withheld impeachment evidence was material; the district court granted habeas relief and ordered release or retrial.
- On appeal the Eleventh Circuit affirmed the district court’s grant of habeas relief as to the Brady claim, concluding the state habeas decision unreasonably applied Brady/Bagley and that the suppressed impeachment evidence undermined confidence in the verdict.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Brady suppression of impeachment evidence | Prosecutor failed to disclose promise to convey Fitzgerald’s helpful testimony to the other prosecutor; this was favorable impeachment evidence and was suppressed | No formal deal existed; any informal statements were immaterial and not Brady material | Held for Williams: suppression of the prosecutorial promise violated Brady because it was impeachment material and was suppressed |
| Materiality of the withheld evidence | The withheld promise was material because Fitzgerald’s testimony was pivotal and disclosure would likely have undermined confidence in the verdict | The state habeas court reasonably found no reasonable probability of a different outcome (not material) | Held for Williams: the withheld evidence was material — there was a reasonable probability of a different result |
| State-court adjudication under AEDPA §2254(d) | State court unreasonably applied Brady/Bagley by failing to treat informal assurances as Brady material | State relied on state habeas factual determination that no deal existed and that any promise was immaterial | Held for Williams: the state habeas decision was an objectively unreasonable application of clearly established federal law regarding impeachment evidence disclosure |
| Cumulative-error claim (prosecutorial misconduct + counsel errors) | The combined effect of nondisclosure and trial counsel’s failures denied a fair trial | State argued cumulative-error relief was unwarranted and ancillary to Brady denial | Not reached on merits by the court because Williams obtained relief on the Brady claim; district court’s cumulative-error ruling left unaddressed by appellate decision |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose evidence favorable to the accused, including impeachment evidence)
- United States v. Bagley, 473 U.S. 667 (1985) (impeachment evidence is Brady material and materiality measured by reasonable probability of different outcome)
- Williams v. State, 722 S.E.2d 847 (Ga. 2012) (state-court opinion recounting trial identifications and rejecting ineffective-assistance claims)
- Wilson v. Warden, Ga. Diagnostic Prison, 834 F.3d 1227 (11th Cir. 2016) (framework for §2254(d) review where state court issues an unexplained summary denial)
- Ponticelli v. Sec’y, Fla. Dep’t of Corr., 690 F.3d 1271 (11th Cir. 2012) (elements and materiality standard for Brady claims)
- Bell v. Cone, 535 U.S. 685 (2002) (definition of "contrary to" and AEDPA standards)
- Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA standards for unreasonable application of Supreme Court precedent)
- Muhammad v. Sec’y, Fla. Dep’t of Corr., 733 F.3d 1065 (11th Cir. 2013) (de novo review of district court’s grant of habeas relief)
- Marshall v. Sec’y, Fla. Dep’t of Corr., 828 F.3d 1277 (11th Cir. 2016) (clarifying the objective unreasonableness standard under AEDPA)