Jon Hall v. Tony Mays, 7 F.4th 433

Background:

In July 1994 Jon Hall murdered his estranged wife; he was convicted of first-degree premeditated murder and sentenced to death in 1997.
At trial a fellow inmate, Chris Dutton, testified about Hall’s admissions; Dutton’s TDOC prison records documenting mental-illness history were not disclosed to defense.
Hall presented mental-health experts and family testimony at trial; post-conviction proceedings produced additional evaluations and mitigation reports but denied relief.
Hall raised a Brady claim (prosecutor withheld Dutton’s mental-health records), an IAC claim that trial counsel should have challenged Hall’s competency, and an IAC claim that counsel failed to present a complete family/social history.
The district court denied habeas relief and COA on most claims; this Court granted COA on the three issues above and AFFIRMED the district court: Brady claim failed; competency IAC procedurally defaulted and unsubstantial; social-history IAC rejected under AEDPA.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady: prosecutor withheld TDOC records showing witness Dutton’s mental illness	Hall: prosecutor had Brady duty to obtain/disclose TDOC records (impeaching evidence); Brady violation would excuse procedural default	State: TDOC records were not in prosecutor’s possession; no showing TDOC acted on prosecutor’s behalf; no Brady duty to obtain records from uninvolved agency; evidence was cumulative and not material	Denied — procedurally defaulted; on merits no imputed government possession or clearly established duty; no materiality/prejudice given cumulative impeachment and overwhelming evidence of guilt
IAC re: failure to challenge competency at trial	Hall: counsel should have moved for competency hearing given his erratic behavior and alleged brain damage; trial-counsel IAC is substantial, so Martinez excused procedural default	State: multiple competency evaluations and expert opinions found Hall competent; counsel reasonably relied on experts; post-conviction counsel not ineffective for not raising meritless claim	Denied — procedurally defaulted; underlying IAC not substantial because experts found competence and counsel reasonably relied on them; Martinez inapplicable
IAC re: inadequate investigation/presentation of family and social-history mitigation	Hall: counsel failed to obtain/present additional family history (mental disorder, family alcoholism, possible head injuries), which likely would have reduced death verdict	State: defense already presented psychological experts and family testimony; mitigation investigators and reports existed; additional evidence would be cumulative; no Strickland prejudice	Denied — state-court decision was a reasonable application of Strickland/AEDPA; additional evidence would be largely cumulative and not sufficiently prejudicial

Key Cases Cited

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (establishes prosecution’s duty to disclose exculpatory and impeachment evidence)
Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (prosecutor must learn of favorable evidence known to others acting on government’s behalf)
Banks v. Dretke, 540 U.S. 668 (U.S. 2004) (Brady materiality and prejudice standard explained)
Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (elements of a Brady claim)
United States v. Bagley, 473 U.S. 667 (U.S. 1985) (reasonable-probability materiality test for undisclosed evidence)
Martinez v. Ryan, 566 U.S. 1 (U.S. 2012) (excuses procedural default where initial-review collateral counsel was ineffective on IAC claim)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance of counsel)
Harrington v. Richter, 562 U.S. 86 (U.S. 2011) (AEDPA deference and "no possibility for fairminded disagreement" standard)
Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (definition of "contrary to" and "unreasonable application" under AEDPA)
Cullen v. Pinholster, 563 U.S. 170 (U.S. 2011) (AEDPA review limited to state-court record)
Brooks v. Tennessee, 626 F.3d 878 (6th Cir. 2010) (Brady procedural-default/actual-prejudice discussion)