Jessie Hoffman v. Burl Cain, Warden, 752 F.3d 430

Hoffman was convicted of first-degree murder in Louisiana and sentenced to death for the killing of Mary Elliot.
Jury found four aggravating circumstances—aggravated rape, aggravated kidnapping, armed robbery, and heinous/cruel murder—to justify the death sentence.
Evidence included kidnapping at gunpoint, ATM withdrawal, videotaped coercion, corroborating girlfriend testimony, and DNA/serology linking Hoffman to Elliot.
State arguments supported premeditation with a theory that the killing occurred at a boat-launch and body then disposed at a dock; the body was later found about 150 feet from the launch.
Hoffman raised claims in state post-conviction and then in federal habeas; the district court denied relief but issued a COA; the Fifth Circuit reviews under AEDPA to assess whether state-court adjudications were reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failing to investigate mitigating evidence	Hoffman argues trial counsel failed to uncover and present mitigating history.	State argues counsel followed ABA guidelines and acted reasonably based on available information.	Denied; state court’s Strickland ruling not unreasonable under AEDPA.
Ineffective assistance for failing to present crime circumstances	Hoffman claims counsel failed to develop and present theory of the crime.	State contends trial strategy reasonably disputed the State’s theory.	Denied; no Strickland deficiency shown for presenting the crime circumstances.
Brady violation for suppressed exculpatory evidence	Hoffman asserts coroner’s report favoring his theory was suppressed.	State contends evidence was not favorable or material.	Denied; no prejudice shown given other aggravating factors.
Batson challenge to race-based jury strikes	Hoffman asserts the strikes of Galatas and Malter were racially motivated.	State provides race-neutral explanations; court deferred to state findings.	Denied; Batson determinations were not shown to be objectively unreasonable.
Racial discrimination by the petit jury; juror affidavit evidence	Hoffman argues juror bias affected verdict.	State argues evidence insufficient; affidavit barred by Rule 606(b) and state law; no substantial prejudice shown.	Denied; no substantial and injurious effect shown; claim procedurally and factually untenable.

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective assistance standard; deficient performance and prejudice)
Harrington v. Richter, 131 S. Ct. 770 (2011) (Richter presumption of merits-review adjudication applies in federal review)
Williams v. Taylor, 529 U.S. 362 (2000) (clear distinction between contrary and unreasonable application under AEDPA)
Cullen v. Pinholster, 131 S. Ct. 1388 (2011) (limits evidence reviewed on habeas to the record before the state court)
Miller-El v. Cockrell (Miller-El I), 537 U.S. 322 (2003) (Batson and jury selection framework; deference to state court findings)
Batson v. Kentucky, 476 U.S. 79 (1986) (race-based peremptory challenges; three-step framework)
Tanner v. United States, 483 U.S. 107 (1987) (juror testimony limited; outside influence exception)
Moody v. Quarterman, 476 F.3d 260 (2007) ( Fifth Circuit discussion on evidentiary considerations in post-conviction claims)
Blue v. Thaler, 665 F.3d 647 (2011) (AEDPA standard application and deference principles)