Lopez v. Ryan, 630 F.3d 1198

Lopez was convicted in 1987 of first-degree murder and related crimes, and sentenced to death based on two aggravating factors: a prior violent felony and an especially heinous, cruel, or depraved murder.
The Arizona Supreme Court remanded for resentencing in 1990 after holding Lopez's prior resisting-arrest conviction did not qualify as a qualifying felony.
At resentencing Lopez again received the death sentence; the Arizona Supreme Court affirmed after independent review of the record.
Lopez petitioned for post-conviction relief; issues included ineffective assistance of counsel (pathological intoxication) and Brady-related claims, as well as a claim that Arizona law impermissibly precluded consideration of mitigating evidence not causally linked to the crime.
The district court denied the habeas petition; the Ninth Circuit reviewed under AEDPA de novo and examined the last reasoned state-court decision.
The court affirmed the district court's denial, upholding the death sentence and rejecting Lopez's claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Lopez receive an individualized sentencing despite a purported causal-nexus rule?	Lopez argues Arizona law required a causal link, eliminating mitigating evidence from consideration.	Ryan contends the state court did consider all mitigating evidence and did not apply an impermissible nexus rule.	No improper nexus found; mitigating evidence considered and found insufficient.
Was there ineffective assistance of counsel at resentencing regarding failing to provide eyewitness data to the psychiatrist under §2254(e)(2)?	Lopez contends counsel failed to furnish eyewitness statements and background data to Dr. Bendheim, undermining the pathological intoxication defense.	Ryan argues Lopez failed to develop the factual basis in state court; evidence shows no prejudice from counsel's actions.	Claim barred under §2254(e)(2); even on merits, insufficient prejudice shown.
Did the government’s failure to disclose the Brady note about an unrelated sexual assault constitute a due process violation or prejudice?	Lopez asserts the note was exculpatory and undisclosed Brady material that could have affected sentencing.	Ryan argues the note was not material Brady evidence and its disclosure would not have changed the outcome.	No Brady violation; note not material and no prejudice established.

Schad v. Ryan, 606 F.3d 1022 (9th Cir. 2010) (clarifies whether state courts applied the correct mitigating-evidence standard post-Tennard)
Lockett v. Ohio, 438 U.S. 586 (U.S. 1978) (requires individualized consideration of mitigating factors)
Tennard v. Dretke, 542 U.S. 274 (U.S. 2004) (clarifies mitigating evidence weight and causal nexus considerations)
Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (limitations on jury fact-finding in capital sentencing )
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance of counsel)
Bagley v. United States, 473 U.S. 667 (U.S. 1985) (materiality standard for Brady disclosures)
Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (AEDPA deference framework for state-court decisions)