Jarrhod Williams v. DeWayne Burton
714 F. App'x 553
| 6th Cir. | 2017Background
- In 2007 Williams confessed to shooting two people; he was charged with two counts of first-degree murder and a felony-firearm count and tried in Michigan state court.
- First bench trial ended in a mistrial after expert testimony suggested two guns were used, undermining the prosecution’s “one-shooter” theory; the original judge recused and a second judge presided at retrial.
- Williams accepted a plea to second-degree murder and felony-firearm (12–30 years plus 2 years) but moved to withdraw the plea before sentencing; defense counsel later argued pretrial that the prosecution should be limited to the one-shooter theory (but characterized the argument as a stretch).
- At retrial a jury convicted Williams of the original charges; he received two life terms without parole plus a consecutive two-year felony-firearm term; state appeals and post-conviction relief were denied.
- Williams filed a 28 U.S.C. § 2254 habeas petition raising ineffective-assistance claims (trial counsel’s advice about the one-shooter theory and conflicts; appellate counsel’s failure to raise these claims) and sought an evidentiary hearing; the district court denied relief but granted a COA limited to the evidentiary-hearing issue and later expanded three substantive claims on appeal.
- The Sixth Circuit affirmed: it held the district court did not abuse its discretion in denying an evidentiary hearing, and rejected Williams’ due-process, trial-ineffectiveness, and appellate-ineffectiveness claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an evidentiary hearing was required on habeas claims | Williams: district court should hold an evidentiary hearing to develop facts about counsel’s advice and conflicts | State: hearing unnecessary because record contradicts Williams’ allegations and he didn’t need a hearing | Denied — district court did not abuse discretion; §2254(e)(2) not a bar but record made claims implausible |
| Whether denial of state-court consideration of a claim violated due process | Williams: state court’s procedural statement barred merits review of the one-shooter advice claim, violating due process | State: any procedural confusion did not deny due process; de novo review is available if state court didn’t decide the claim | No due process violation; district court’s AEDPA application was incorrect but error did not deny due process; affirmed |
| Whether trial counsel was ineffective for advising (or prompting withdrawal based on) the one-shooter theory, impacting plea decision | Williams: counsel misadvised that prosecution would be limited to the one-shooter theory, causing him to withdraw a favorable plea | State: record contradicts that counsel believed that theory or advised withdrawal on that basis; Williams’ signed statement explaining withdrawal did not cite that advice | Not ineffective — record refutes deficient performance; Strickland/Hill/Lafler prejudice not shown; affirmed |
| Whether appellate counsel was ineffective for not raising the trial-counsel claims on direct appeal | Williams: appellate counsel erred by omitting the one-shooter/advice claim | State: appellate counsel reasonably winnowed weaker claims; no evidence counsel knew of a viable one-shooter-advice claim | Not ineffective — under Strickland and AEDPA’s doubly deferential review, failure to raise that claim was reasonable; affirmed |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (performance and prejudice test for ineffective assistance of counsel)
- Hill v. Lockhart, 474 U.S. 52 (Strickland applies to challenges to guilty pleas)
- Lafler v. Cooper, 566 U.S. 156 (prejudice standard when counsel’s advice leads a defendant to reject or withdraw a plea)
- Schriro v. Landrigan, 550 U.S. 465 (district court need not hold evidentiary hearing when record refutes allegations)
- Harrington v. Richter, 562 U.S. 86 (AEDPA requires state-court decision be objectively unreasonable)
- Michael Williams v. Taylor, 529 U.S. 420 (diligence requirement for development of facts in state court under §2254)
- Maples v. Stegall, 340 F.3d 433 (6th Cir.) (de novo review when state courts did not address the federal ineffective-assistance claim)
- Cullen v. Pinholster, 563 U.S. 170 (AEDPA deference constrains evidentiary development and review of counsel performance)
- Burt v. Titlow, 134 S. Ct. 10 (doubly deferential review when Strickland claims are reviewed under AEDPA)