Michael Meyers v. David Gomez, 50 F.4th 628

In 1989 seven Gangster Disciples members (including Michael Meyers) were tried and convicted for two murders; key eyewitness testimony came from Deanda Wilson and victim-witness A.W.
Wilson testified at trial identifying Meyers as one of seven shooters; he later recanted in multiple post-trial statements and at a postconviction hearing.
Sherri Parker, an alleged alibi witness who said Meyers was at her apartment when the shots rang out, was subpoenaed but not called at trial; trial counsel George Nichols did not interview her (disputed).
Meyers’ counsel moved to exclude Meyers’ post‑arrest statements admitting presence at the scene; the State withdrew its request to admit them at trial, but the court had signaled willingness to admit redacted versions.
State postconviction proceedings: judge credited Wilson’s trial testimony as to Meyers (discredited recantation for Meyers), rejected Napue claim (no knowing use of perjury), but later vacated convictions for two co‑defendants; Illinois appellate court ordered an evidentiary hearing on ineffective assistance re: Parker and ultimately affirmed the denial for Meyers.
Federal habeas: district court denied relief; Seventh Circuit affirmed, holding the state courts reasonably applied Strickland and that the Napue claim was procedurally defaulted and, alternatively, lacked proof the State knowingly used perjury.

Issue	Plaintiff's Argument (Meyers)	Defendant's Argument (State)	Held
Ineffective assistance for failing to interview/call alibi witness Parker	Nichols never interviewed Parker and thus could not make an informed strategic choice; failing to present Parker prejudiced the defense under Strickland	Nichols knew of Parker, subpoenaed her, and reasonably declined to call her because her testimony would have opened the door to Meyers’ damaging post‑arrest statements; state courts’ finding was reasonable	Affirmed: state court’s application of Strickland was not unreasonable under AEDPA; Nichols’ choice could be a legitimate strategic decision and not proven ineffective
Due process violation / Napue — State’s alleged knowing use of perjured testimony (Wilson)	Wilson’s recantations show his trial ID was false and the prosecution knowingly used perjured testimony to convict Meyers	Meyers procedurally defaulted the federal Napue claim in state court; state postconviction judge credited prosecutor and found no knowing use of perjury	Affirmed: claim procedurally defaulted; alternatively, state court’s factual finding that the State did not knowingly present perjured testimony was reasonable and Meyers failed to rebut it with clear and convincing evidence

Strickland v. Washington, 466 U.S. 668 (establishes deficient performance and prejudice test for ineffective assistance of counsel)
Napue v. Illinois, 360 U.S. 264 (prosecution’s knowing use of perjured testimony violates due process)
Harrington v. Richter, 562 U.S. 86 (deference to state court decisions under AEDPA and limits on post hoc rationalization of counsel’s strategy)
Knowles v. Mirzayance, 556 U.S. 111 (doubly deferential review when AEDPA and Strickland overlap)
Wiggins v. Smith, 539 U.S. 510 (limits on courts inventing strategic bases for counsel’s choices)
Kimmelman v. Morrison, 477 U.S. 365 (counsel’s duty to investigate; role of defense investigation in adversarial testing)
Woods v. Donald, 575 U.S. 312 (standard for unreasonable application under AEDPA)
Williams v. Taylor, 529 U.S. 362 (framework for AEDPA deference to state-court decisions)