Lawrence Landrum v. Carl Anderson, 813 F.3d 330

Landrum was convicted of aggravated burglary and aggravated murder in 1985, with two death-penalty specifications at issue.
Coffenberger–Swackhammer statements were alleged to exculpate Landrum and could have affected guilt-phase strategy if admitted.
Landrum pursued state post-conviction relief and later habeas petitions in federal court, with litigation over procedural default and ineffective-assistance-of-counsel claims.
The district court granted a conditional writ based on ineffective-assistance-of-post-conviction counsel and allowed merits review of the Coffenberger claim; the court later denied relief on the merits.
This court previously held Landrum procedurally defaulted the Coffenberger claim and that post-conviction counsel could not constitute cause; Martinez and Trevino later shaped arguments for relief.
The panel ultimately affirms the district court’s denial of Rule 60(b) relief on alternative grounds, finding no substantial claim of ineffective assistance of trial counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Martinez/Trevino justify Rule 60(b) relief	Landrum argues post-conviction counsel’s ineffectiveness excuses default and allows merits review.	Warden contends no extraordinary circumstances warrant reopening; no substantial claim shown.	Not warranted; no substantial showings of extraordinary circumstance to reopen.
Whether Coffenberger claim shows prejudice	Landrum's counsel’s failure to present Coffenberger's statement was deficient and potentially decisive.	Evidence supports guilt despite the omission; Coffenberger testimony would not have created reasonable doubt.	No reasonable probability of acquittal or failure to find principal offender even if admitted.
Whether law-of-the-case or other grounds require reversal	Landrum seeks relief by re-evaluating merits in light of Martinez/Trevino.	No basis to disturb the prior ruling beyond the Rule 60(b) analysis.	Affirmed on alternative grounds; no abuse of discretion in denying relief.

Martinez v. Ryan, 132 S. Ct. 1309 (Supreme Court (2012)) (ineffective post-conviction counsel can excuse procedural default for some claims)
Trevino v. Thaler, 133 S. Ct. 1911 (Supreme Court (2013)) (extends Martinez to state-law procedural frameworks)
Gonzalez v. Crosby, 545 U.S. 524 (Supreme Court (2005)) (extraordinary-circumstances standard for Rule 60(b)(6) relief)
Henness v. Bagley, 766 F.3d 550 (6th Cir. 2014) (whether Trevino justifies Rule 60(b) relief under Ohio law)
McGuire v. Warden, Chillicothe Corr. Inst., 738 F.3d 741 (6th Cir. 2013) (application of Martinez/Trevino to Ohio-like contexts)
Landrum v. Mitchell, 625 F.3d 905 (6th Cir. 2010) (procedural default and cause for a post-conviction claim; ineffective-assistance of appellate counsel)
Strickland v. Washington, 466 U.S. 668 (Supreme Court (1984)) (deficient performance and prejudice standard)
Hinton v. Alabama, 134 S. Ct. 1081 (Supreme Court (2014)) (prejudice inquiry in Strickland for capital cases)