Meier Jason Brown v. United States
2013 U.S. App. LEXIS 13941
| 11th Cir. | 2013Background
- Brown was convicted in the district court of murder and robbery under federal statutes arising from a post office robbery in Fleming, Georgia, resulting in Sallie Gaglia’s death during the offense.
- Penalty-phase evidence included government witnesses detailing Brown’s extensive criminal history and Brown’s mitigation witnesses describing his family, caretaking, and community standing.
- The jury found seven aggravating factors beyond a reasonable doubt, leading to a death sentence for the murder convictions and a 300-month sentence for robbery.
- Brown appealed, challenging evidentiary and constitutional errors, voir dire, and Brady/Miranda issues; we affirmed on direct appeal in Brown v. United States, 441 F.3d 1330 (11th Cir. 2006).
- Brown later sought § 2255 relief, arguing ineffective assistance of penalty-phase counsel for failure to investigate mitigation and mental health, a claim about juror Rentz’s voir dire, and conflict-free counsel; the district court denied relief and Brown appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Penalty-phase mitigation: deficient investigation? | Brown | United States | No prejudice; evidence was cumulative and insufficient to alter sentencing |
| Penalty-phase mental health evidence: deficient investigation? | Brown | United States | No prejudice; added evidence would not have changed balancing of aggravation and mitigation |
| Rentz voir dire: absence of record violated Witherspoon? | Brown | United States | Waived/defaulted; no reversible error and no prejudice from missing transcript |
| Conflict-free § 2255 counsel: requirement met? | Brown | United States | District court did not abuse discretion; no substantial conflict affecting representation |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes performance and prejudice prongs for ineffectiveness)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (reweighs mitigation evidence against aggravation for prejudice in capital cases)
- Witherspoon v. Illinois, 391 U.S. 510 (U.S. 1968) (jury impanelment cannot exclude for general opposition to death penalty)
- Morgan v. Illinois, 504 U.S. 719 (U.S. 1992) (requires opportunity to determine jurors’ death-penalty views during voir dire)
- Martel v. Clair, 132 S. Ct. 1276 (S. Ct. 2012) (test for substituting counsel in capital § 3599 proceedings; factors to consider)