Martin Woolley v. Dave Rednour
2012 U.S. App. LEXIS 25558
| 7th Cir. | 2012Background
- Martin Woolley was charged in Illinois state court with murder, armed violence, armed robbery, and unlawful possession of a firearm by a felon for 1995 tavern killings.
- He initially confessed, later recanted, claiming his wife Marcia committed the murders; the jury convicted him on all counts.
- In state post-conviction proceedings, an expert (Busch) later challenged the State’s crime-scene evidence, suggesting the shooter was near the barstools.
- Stockton, Woolley’s trial counsel, did not obtain an expert to rebut the State’s evidence or request a continuance despite untimely disclosures about the new expert opinion.
- Woolley argued ineffective assistance of counsel under Strickland; the state court found no prejudice, while the appellate court did not reach the performance prong.
- The district court denied habeas relief but granted a certificate of appealability on the prejudice prong; on appeal, the Seventh Circuit applied AEDPA review and affirmed the district court’s denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counsel's performance was deficient | Woolley argues Stockton failed to retain an expert and respond to late disclosures. | Woolley contends the appellate court should defer to the state court's finding or apply AEDPA deference. | Performance deemed deficient; prejudice must be assessed under AEDPA. |
| Whether Woolley was prejudiced by counsel's deficient performance | Ogryzek's unrebutted testimony destroyed Woolley's alibi; expert testimony could have changed outcome. | Evidence against Woolley was overwhelming; alterations would not likely change verdict. | No reasonable probability of different outcome; prejudice not established. |
| Applicable standard of review for Strickland prongs on AEDPA review | Last reasoned state court decision governs review; de novo where prong unaddressed. | AEDPA applies deference or Straw arguments about Harrington apply. | Review conducted de novo for performance prong; AEDPA deferential for prejudice prong. |
| Whether the Illinois appellate court reasonably determined no prejudice | Ogryzek's testimony alone could not sustain guilt without Woolley's credibility issues. | Record shows multiple independent incriminating sources; prejudice not shown in context. | Appellate court’s prejudice finding not unreasonable under the record. |
| Whether the district court properly granted habeas relief under Strickland and AEDPA | District court was correct in applying de novo review for performance and deferring on prejudice where facts supported. | Court should defer more to state court determinations under AEDPA. | District court’s ruling affirmed; no habeas relief. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance of counsel)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (AEDPA deference; totality of evidence standard)
- Harrington v. Richter, 131 S. Ct. 770 (S. Ct. 2011) (unexplained state court decisions may be adjudications on the merits)
- Ylst v. Nunnemaker, 501 U.S. 797 (U.S. 1991) (last reasoned state decision governs under AEDPA pass-through rule)
- Knowles v. Mirzayance, 556 U.S. 111 (U.S. 2009) (limits habeas relief where federal courts defer to state court's decisions)