Jimmy Meders v. Warden, Georgia Diagnostic Prison
911 F.3d 1335
11th Cir.2019Background
- In 1987 Jimmy Fletcher Meders was convicted of malice murder and armed robbery after a Jiffy Store clerk was shot; the murder weapon (.357 Magnum) was later found under Meders’ waterbed and bait money from the register was found in his possession. Meders was sentenced to death.
- At trial three eyewitnesses (Harris, Arnold, Creel) and police testified; Meders admitted possession of the stolen cash and ownership of the .357 but claimed Arnold shot the clerk. Meders initially denied involvement to police and only implicated himself over a year later.
- On direct appeal the Georgia Supreme Court remanded for an evidentiary hearing on newly raised ineffective-assistance claims about trial counsel’s failure to use pretrial statements/police reports and to object to certain exhibits; the state courts ultimately rejected Meders’ ineffective-assistance claim.
- Meders pursued state habeas relief (initially granted, later reversed by the Georgia Supreme Court as previously litigated) and then filed federal habeas under 28 U.S.C. § 2254.
- The district court found deficient performance but concluded the state court’s prejudice determination was not an unreasonable application of Strickland under AEDPA and denied relief; Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for failing to use pretrial witness statements and police reports to impeach State witnesses | Meders: counsel’s failure to present impeachment (pretrial statements, truck-shooting reports) undermined witness credibility and, cumulatively, created a reasonable probability of a different result | State: impeachment material was largely cumulative and would not overcome strong physical and testimonial evidence of guilt | Held: No; under AEDPA deference, the state court’s finding of no Strickland prejudice was not unreasonable |
| Whether counsel was ineffective for failing to object to admission of food stamps | Meders: food stamps were not traced to the store and counsel should have objected | State: witness testimony tied food stamps to the robbery (found on Meders; Creel’s testimony that Meders offered stamps) so objection would have been futile | Held: No; admission was reasonably supported and failure to object was not prejudicial |
| Whether counsel was ineffective for failing to object to a citation for cocaine sales found in his wallet | Meders: citation prejudicial and counsel should have objected | State: citation was never argued to jury, Meders admitted drug use at trial, and it was not a critical fact for guilt | Held: No; any error was not prejudicial and a fairminded jurist could agree with state court |
| Whether federal habeas court should overturn state-court Strickland ruling under AEDPA | Meders: argues state court misvalued impeachment and evidence, implying deference should not block relief | State: AEDPA requires deferential review; the state court’s reasons and outcome survive as reasonable | Held: AEDPA deference applies; because some fairminded jurist could agree with the state court, federal habeas relief denied |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes ineffective-assistance two-part test requiring deficient performance and prejudice)
- Harrington v. Richter, 562 U.S. 86 (AEDPA deference; likelihood of different result must be substantial, not merely conceivable)
- Wilson v. Sellers, 138 S. Ct. 1188 (look-through principle for state-court decisions when higher court affirms without opinion)
- Virginia v. LeBlanc, 137 S. Ct. 1726 (state-court decision must be objectively unreasonable, not merely wrong, to overcome AEDPA)
- Johnson v. Williams, 568 U.S. 289 (federal courts cannot impose mandatory opinion-writing standards on state courts)