Martinez v. Quick, 134 F.4th 1046

Mica Martinez was convicted by an Oklahoma jury of two counts of first-degree murder and one count of assault and battery with a dangerous weapon, and sentenced to death for the murders.
The murders involved Martinez breaking into a home, attacking and killing the residents, after a night of heavy drinking; his defense focused on lack of premeditation and intoxication.
At sentencing, prosecution introduced evidence of Martinez’s use of a racial slur in a prior altercation; the defense objected, but the jury was instructed to disregard it.
On direct appeal, the Oklahoma Court of Criminal Appeals (OCCA) affirmed Martinez’s conviction and sentence, rejecting claims of ineffective assistance of counsel (IAC), unfair sentencing due to the racial slur evidence, and cumulative error.
Martinez sought federal habeas relief on grounds of ineffective appellate and trial counsel for failure to investigate and present mitigating family testimony, unfair sentencing from prejudicial evidence, and cumulative error; both district court and circuit court denied relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective Assistance—Failure to Investigate Family Mitigation	Martinez claims appellate counsel was ineffective for not arguing that trial counsel failed to investigate and present important mitigating testimony from his family.	The state contends trial and appellate counsel conducted reasonable investigations, acted strategically, and presented substantial mitigation evidence, so no deficiency occurred.	No unreasonable application of Strickland; trial/appellate counsel’s performance was reasonable. Relief denied.
Unfair Sentencing—Introduction of Racial Slur	The introduction of a witness’s racial slur during sentencing rendered the proceeding fundamentally unfair and violated Martinez’s rights.	The slur was an unexpected, isolated remark cured by an immediate instruction to the jury; thus, there was no fundamental unfairness.	The testimony was not so prejudicial as to render the sentencing fundamentally unfair; relief denied.
Cumulative Error	Multiple errors in the proceedings collectively denied Martinez a fair trial/sentencing.	No errors occurred, so cumulative error analysis is inapplicable.	No errors found; cumulative error claim rejected.
Evidentiary Hearing in Habeas	Martinez was entitled to an evidentiary hearing on his habeas claims.	The factual record was sufficient and did not trigger the need for a new hearing under the applicable AEDPA standard.	No evidentiary hearing required under § 2254(d); relief denied.

Strickland v. Washington, 466 U.S. 668 (establishes the two-prong test for ineffective assistance of counsel claims)
Rompilla v. Beard, 545 U.S. 374 (scope of counsel’s duty to investigate mitigating evidence in capital cases)
Caldwell v. Mississippi, 472 U.S. 320 (limit on misleading jury about its role in capital sentencing)
Payne v. Tennessee, 501 U.S. 808 (due process standard for prejudicial evidence at sentencing)
Darden v. Wainwright, 477 U.S. 168 (clarifies Caldwell’s application to jury responsibility in sentencing)
Woodson v. North Carolina, 428 U.S. 280 (plurality; reliability required in capital sentencing procedures)
Cullen v. Pinholster, 563 U.S. 170 (limits federal habeas review to state court record)
Brecht v. Abrahamson, 507 U.S. 619 (harmless error standard in federal habeas review)