Joseph Hart v. Ron Broomfield, 97 F.4th 644

In 1988, Joseph William Hart was convicted of murdering Diane H. (Diane), and raping, sodomizing, and forcing oral copulation on Amy R., both 15-year-old girls whom Hart lured to a rural area in Riverside County, CA.
At trial, the prosecution presented both direct and circumstantial evidence, including Amy's testimony, forensic evidence linking Hart to the murder and assaults, and expert testimony by Dr. Dewitt Hunter regarding Diane's autopsy.
Hart was sentenced to death, with the penalty phase including evidence of prior assaults and another alleged murder (that of his niece, Shelah).
Hart's conviction and sentence were affirmed by the California Supreme Court, and subsequent state and federal habeas petitions were denied.
On federal habeas review, Hart asserted Brady and ineffective assistance of counsel (IAC) claims related to Dr. Hunter’s qualifications/testimony; the district court denied relief, and Hart appealed the denial on those certified issues.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Alleged Brady Violation: Suppression of Impeachment Evidence on Dr. Hunter	State suppressed evidence of Hunter's errors in prior cases, which could have undermined his credibility and the reliability of his findings.	Prosecution did not have some impeachment evidence at time of trial; alleged errors were immaterial to core facts and findings in this case.	No Brady violation; reasonable for court to find impeachment evidence not material—other evidence supported verdict.
Ineffective Assistance of Counsel: Failure to Challenge Dr. Hunter	Trial counsel was ineffective in not challenging Hunter’s qualifications or investigating Hunter’s credibility.	Dr. Hunter was qualified; challenge would have been futile or possibly detrimental given his “mixed” testimony.	Counsel’s performance did not prejudice Hart; thus, no IAC violation.
Ineffective Assistance of Counsel: Failure to Present Counter-Expert	Counsel failed to present expert testimony to rebut Dr. Hunter.	No showing another expert would have contradicted Hunter; argument speculative.	No prejudice shown; speculative assertions insufficient for IAC claim.
Incomplete State Court Record for Brady/IAC Issues	State courts unjustly denied evidentiary hearing, rendering record incomplete.	State courts had sufficient record; Hart did not specify what further evidence would be material.	No error; state court’s findings reasonable based on available evidence.

Brady v. Maryland, 373 U.S. 83 (Suppression of material exculpatory or impeaching evidence violates due process)
Giglio v. United States, 405 U.S. 150 (Impeachment evidence falls within Brady rule)
Strickland v. Washington, 466 U.S. 668 (Standard for ineffective assistance of counsel claims)
Kyles v. Whitley, 514 U.S. 419 (Materiality standard under Brady)
Williams v. Taylor, 529 U.S. 362 (AEDPA standard for federal habeas review)
Harrington v. Richter, 562 U.S. 86 (Unexplained state court denials reviewed for any reasonable basis under AEDPA)
Knowles v. Mirzayance, 556 U.S. 111 (Deference required under AEDPA for IAC claims)