Jeffrey Workman v. Superintendent Albion SCI, 915 F.3d 928

In Aug. 2006 Workman fired at a shooter (Moses); a ricocheted bullet from Workman struck Lawson Hunt, who died; medical testimony could not definitively say which bullet was fatal and indicated Hunt was alive when Workman’s bullet hit.
At trial Workman was convicted of first‑degree murder under transferred intent; trial counsel advanced the theory that Hunt was already dead from Moses’s shot and therefore Workman could not have killed him.
Trial counsel called no witnesses, presented no defense evidence, cross‑examined narrowly, made a contradictory closing argument, and requested instructions but did not develop manslaughter or defense‑of‑others theories.
PCRA counsel raised only a weak, narrowly framed claim about a jury instruction; he did not raise trial counsel’s failure to present a cogent defense. The state courts rejected the PCRA claim.
Workman sought federal habeas relief under 28 U.S.C. § 2254, arguing ineffective assistance of trial counsel; the District Court dismissed, holding Workman had not shown Martinez cause to excuse procedural default.
The Third Circuit excused the procedural default under Martinez, found PCRA counsel constitutionally deficient, held trial counsel’s performance was objectively unreasonable and prejudicial under Strickland, and instructed the district court to grant a conditional writ of habeas corpus.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether procedural default of trial‑IAC claim is excused under Martinez	Workman: PCRA counsel was ineffective for failing to raise trial‑counsel’s failure to present a cogent defense; thus Martinez allows review	Commonwealth: Workman cannot show PCRA counsel was ineffective, so Martinez does not apply	Held: Martinez applies — PCRA counsel was deficient and the underlying claim has "some merit," so default is excused
Whether trial counsel rendered ineffective assistance (performance)	Workman: counsel failed to test Commonwealth’s case, presented no witnesses, pursued a contradicted theory	Commonwealth: evidence sufficient; strategic choices presumed reasonable	Held: Counsel’s performance was objectively unreasonable given failure to respond to medical testimony and to present any defense witnesses or coherent strategy
Whether trial counsel’s deficient performance was prejudicial (Strickland prejudice)	Workman: but for counsel’s errors, reasonable probability of different outcome (plea rejection, not testifying)	Commonwealth: strong case supported conviction; no specific alternate actions shown	Held: Prejudice shown — confidence in outcome undermined; reasonable probability of different result
Remedy on habeas	Workman: asks for relief based on IAC excusing default	Commonwealth: opposes relief	Held: District Court order vacated; remanded with instructions to grant a conditional writ of habeas corpus

Martinez v. Ryan, 566 U.S. 1 (2012) (creates narrow exception allowing cause to excuse procedural default when initial‑review collateral counsel is ineffective)
Miller‑El v. Cockrell, 537 U.S. 322 (2003) (standard for certificate of appealability and when claims are "substantial")
Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong test for ineffective assistance: performance and prejudice)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard)
Trevino v. Thaler, 569 U.S. 413 (2013) (applies Martinez framework to additional state‑law contexts)
Detrich v. Ryan, 740 F.3d 1237 (9th Cir. 2014) (interpretation of Martinez’s prejudice and cause requirements)
Brown v. Brown, 847 F.3d 502 (7th Cir. 2017) (adopts approach distinguishing Strickland prejudice from Martinez cause)