Marbel Mendoza v. Secretary, Florida Department of Corrections, 761 F.3d 1213

Mendoza, a Florida inmate, challenged his capital conviction for first-degree felony-murder and death sentence in a §2254 petition.
District court denied the petition; this Court granted COA on ineffective assistance of counsel during penalty phase mitigation.
Pre-trial, Mendoza was evaluated by multiple mental health professionals; Dr. Haber and Dr. Toomer prepared reports; Dr. Haber did not testify at trial.
Penalty phase included mitigation focusing on mental health, traumatic childhood, and Mendoza’s background; experts testified and evidence was introduced.
State introduced aggravating factors; jury recommended death by 7-5; state court sentenced Mendoza to death after final hearing.
Mendoza filed post-conviction relief (Rule 3.850); Florida courts and Florida Supreme Court reviewed under Strickland with AEDPA deference.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Penalty-phase mitigation investigation deficient?	Mendoza contends counsel failed to investigate/present mitigation adequately.	State argues investigation was thorough and relied on qualified experts; no deficiency.	No deficient performance; Strickland-AEDPA deferential standard satisfied.

Strickland v. Washington, 466 U.S. 668 ((1984)) (two-prong standard for ineffective assistance)
Williams v. Taylor, 529 U.S. 362 ((2000)) (establishes clearly established federal law standard for AEDPA)
Harrington v. Richter, 563 U.S. 86 ((2011)) (doubly deferential review under Strickland and AEDPA)
Knowles v. Mirzayance, 556 U.S. 111 ((2009)) (highly deferential review under AEDPA for state-court decisions)
Wiggins v. Smith, 539 U.S. 510 ((2003)) (duty to uncover and present mitigating evidence)
Rompilla v. Beard, 545 U.S. 374 ((2005)) (conditioning trial strategy on available information; prejudice inquiry)
Cullen v. Pinholster, 563 U.S. 170 ((2011)) (AEDPA review of evidence at state post-conviction; limitations on new evidence)