John Troy v. Secretary, Florida Department of COrrections, 763 F.3d 1305

Troy sought habeas relief challenging the penalty-phase exclusion of corrections officer Galemore’s testimony; Galemore had no personal contact with Troy and would discuss hypothetical life-prison conditions.
Florida Supreme Court and the district court rejected Troy’s claim that exclusion violated Eighth/Fourteenth Amendment rights to mitigate evidence and to present a complete defense.
Troy was convicted of first-degree murder in a brutal killing of Bonnie Carroll, with extensive aggravating factors and substantial mitigation presented by 29 witnesses.
The penalty phase included four statutory aggravators and multiple mitigating factors, and the jury recommended death by an eleven-to-one vote.
AEDPA governs review; the district court denied relief; on appeal, the Eleventh Circuit held the Florida court’s decision was not contrary to or an unreasonable application of Supreme Court law and that any error was harmless under Brecht; a concurrence noted a potential constitutional question but agreed with harmlessness.
The opinion affirms the denial of habeas relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether excluding Galemore’s testimony violated mitigation rights	Troy	Troy’s claim denied; Galemore would provide relevant mitigation	No reversible error; exclusion was not clearly established as constitutional error
Whether exclusion violated right to a complete defense	Troy	State allowed other mitigation and cross-examination	No due-process violation; exclusion was permissible under governing law
Harmlessness of the error under Brecht standard	Troy	Mitigating evidence already extensive	Harmless error; no substantial effect on death recommendation
AEDPA deference and standard of review	Troy	Florida court reasonably applied law	Not entitled to relief under § 2254(d)(1); even de novo review supports denial

Lockett v. Ohio, 438 U.S. 586 (1978) (mitigation scope cannot be limited to defendant’s character or offense circumstances)
Eddings v. Oklahoma, 455 U.S. 104 (1982) (personalized mitigation essential to capital sentencing)
Crane v. Kentucky, 476 U.S. 683 (1986) (due-process limits on excluding defense evidence; gatekeeping authority)
Skipper v. South Carolina, 476 U.S. 1 (1986) (mitigation evidence about future behavior may be relevant)
Gardner v. Florida, 430 U.S. 349 (1977) (due process when the death sentence rests on information defendant could not deny or explain)
Simmons v. South Carolina, 512 U.S. 154 (1994) (parole-related information may be mitigating; life without parole context)
Tennard v. Dretke, 542 U.S. 274 (2004) (relevance standard for mitigating evidence is low threshold but meaningful)
Brecht v. Abrahamson, 507 U.S. 619 (1993) (harmless-error standard for habeas corpus)
Williams v. Taylor, 529 U.S. 362 (2000) (establishes §2254(d) governing review; reasonable application)
Harrington v. Richter, 562 U.S. 86 (2011) (unreasonable application standard for federal review)