798 F.3d 405
6th Cir.2015Background
- LaMar was convicted of murdering five inmates during an Ohio prison riot; four killings yielded death sentences and one yielded a life sentence.
- He raised multiple federal-habeas claims including a Brady violation, severance, sufficiency of a kidnapping aggravator, and prosecutorial misconduct.
- The Warden cross-appealed alleging the petition was time-barred; the district court ruled against relief and denied amendments.
- AEDPA governs the petition; the panel reviews state-court adjudications under deferential standards for merits.
- The court ultimately affirmed the district court’s denial of relief on the merits, rejecting each asserted claim.
- The underlying riot involved multiple inmate groups and a “death squad” that attacked snitch-inmates in L-Block and later in the recreation yard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady violation and prejudice | LaMar asserts suppressed favorable evidence tainted guilt. | State contends no prejudice; evidence either not suppressed or not material. | Brady claim fails; no prejudice shown. |
| Severance of Weaver count | LaMar alleges misjoinder contaminated the Weaver count. | State argues no due-process prejudice; severance not required. | Denial of severance did not violate due process. |
| Kidnapping aggravators sufficiency | LaMar contends kidnapping aggravators lacked sufficient proof. | State maintained aggravators supported by the record. | Sufficient aggravators supported the verdict; any error harmless. |
| Prosecutorial misconduct | LaMar claims prosecutorial misconduct violated due process. | State asserts misconduct, if any, was harmless and cured by reweighing. | No constitutional violation; any misconduct harmless and cured. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (federal standard for suppressed evidence material to guilt or punishment)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (materiality and suppression considerations in Brady claims)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (definition of favorable evidence and prejudice)
- Harrington v. Richter, 562 U.S. 86 (U.S. 2011) (unreasonable-application review standard for state-court decisions)
- Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (clarifies unreasonable-application framework; use holdings not dicta)
- Donnelly v. DeChristoforo, 416 U.S. 637 (U.S. 1974) (pretrial prosecutorial conduct standard in due-process analysis)