Jeffrey Workman v. Superintendent Albion SCI
903 F.3d 368
3rd Cir.2018Background
- In Aug. 2006 Lawson Hunt was shot twice in Philadelphia; Gary Moses fired one bullet and Jeffrey Workman fired a ricocheted bullet that also struck Hunt; medical testimony indicated either shot could have been fatal and suggested Hunt was alive when Workman’s bullet struck.
- Workman was tried in Pennsylvania for first‑degree murder under a transferred‑intent theory (intent to kill Moses transferred to Hunt) and was convicted; he received life without parole.
- At trial Workman’s counsel rested without calling witnesses or presenting expert/fact testimony and pursued a theory that Hunt was already dead from Moses’s shot so Workman could not have killed him. Counsel did not effectively respond to the medical examiner’s testimony that Hunt was alive when struck by Workman’s bullet.
- In state PCRA proceedings appointed PCRA counsel raised only a strained claim about jury instructions relating to transferred intent and self‑defense; PCRA counsel did not present the clearer claim that trial counsel failed to present a cogent defense. The Superior Court rejected the claimed instruction error as meritless.
- Workman filed a § 2254 habeas petition alleging ineffective assistance of trial counsel; the District Court dismissed, finding Martinez did not excuse procedural default. The Third Circuit granted COA limited to the claim that trial counsel gave erroneous advice and failed to present a cogent defense.
- The Third Circuit held PCRA counsel’s omission was deficient under Strickland/Martinez and that trial counsel’s near‑total failure to subject the prosecution’s case to meaningful testing violated the Sixth Amendment, so habeas relief should be granted conditionally.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martinez v. Ryan excuse applies to a procedurally defaulted ineffective‑assistance‑of‑trial‑counsel claim | Workman: PCRA counsel was ineffective for failing to raise trial counsel’s failure to present a cogent defense, so Martinez permits federal review of the defaulted claim | Respondents: Workman cannot show PCRA counsel was ineffective; default stands | Held: Martinez applies — PCRA counsel’s performance was deficient and the underlying claim has “some merit,” so procedural default is excused |
| Whether PCRA counsel’s failure to raise the cogent‑defense claim was deficient under Strickland | Workman: PCRA counsel omitted an obvious, substantial issue and pursued a weaker, doomed instruction claim | Respondents: PCRA counsel’s choices were tactical and reasonable | Held: Omission was not a reasonable tactical choice; PCRA counsel was deficient under Strickland performance prong |
| Whether trial counsel’s performance was constitutionally ineffective for failing to present a meaningful defense | Workman: Trial counsel rested, called no witnesses, ignored/contradicted medical testimony, and advanced an implausible theory that prevented meaningful adversarial testing | Respondents: Evidence was sufficient and counsel’s choices were presumptively tactical | Held: Trial counsel’s failures amounted to near‑total failure to test the prosecution’s case (Cronic), falling below objective reasonableness and violating the Sixth Amendment |
| Remedy: Whether habeas relief is warranted and what form | Workman: Entitled to habeas relief because counsel denied effective assistance and default excused | Respondents: Conviction supported by sufficient evidence; no relief | Held: Reverse District Court and remand with instructions to grant a conditional writ of habeas corpus |
Key Cases Cited
- Martinez v. Ryan, 566 U.S. 1 (2012) (creates limited exception allowing federal review when initial‑review collateral counsel was absent or ineffective)
- Miller‑El v. Cockrell, 537 U.S. 322 (2003) (guidance on what makes a claim "substantial" for COA/Martinez analyses)
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong test for ineffective assistance: performance and prejudice)
- United States v. Cronic, 466 U.S. 648 (1984) (presumptive prejudice where counsel fails to subject prosecution to meaningful testing)
- Trevino v. Thaler, 569 U.S. 413 (2013) (clarifies Martinez application in certain state procedures)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
- Detrich v. Ryan, 740 F.3d 1237 (9th Cir. 2014) (interprets Martinez’s cause and prejudice framework)
- Brown v. Brown, 847 F.3d 502 (7th Cir. 2017) (adopts approach that deficient PCRA counsel performance can be shown without full Strickland prejudice when underlying claim is substantial)