Nanon Williams v. Rick Thaler, Director
2012 U.S. App. LEXIS 12532
| 5th Cir. | 2012Background
- Williams was convicted of capital murder in Texas in 1995 and sentenced to death; the Texas Court of Criminal Appeals (CCA) affirmed on direct appeal.
- In state habeas, Williams obtained ballistics and pathology evidence suggesting EB-1 originated from a .22-caliber pistol, not a .25-caliber pistol, potentially undermining trial counsel’s strategy.
- The state habeas trial court found trial counsel’s failure to obtain independent experts constituted ineffective assistance under Strickland, recommending relief.
- The CCA denied relief in a brief two-page order, without detailed reasoning, denying Williams’s habeas petition.
- Williams then sought federal habeas relief; the district court granted relief on the Strickland claim, and this court later reversed that grant on appeal.
- AEDPA governs federal review of the state-court decision, requiring deference unless the state court’s decision was unreasonable under §2254(d).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the CCA’s denial an unreasonable application of Strickland? | Williams argues failure to obtain independent experts deprived him of a meaningful defense. | Williams’s claim was evaluated under highly deferential AEDPA standard; record supports denial. | No; CCA’s decision not unreasonable under Strickland and AEDPA. |
| Does Pinholster limit review to the state-court record for §2254(d)(1)? | Post-conviction evidence should inform prejudice/findings under Strickland. | Pinholster confines review to the record before the state court; federal evidentiary postures are irrelevant. | Yes; review limited to the state-court record. |
| Did Williams suffer prejudice given the available record before the CCA? | Independent ballistics/pathology evidence would have changed the outcome, showing lack of causation by Williams. | Even with new evidence, record showed Williams was the only person with a shotgun and the trial testimony could sustain guilt. | Not reasonably likely the outcome would have changed; prejudice not shown. |
Key Cases Cited
- Williams v. Quarterman, 551 F.3d 352 (5th Cir. 2008) (administrative evidentiary hearing and standard for applying AEDPA pre-Pinholster)
- Pinholster v. Cullen, 131 S. Ct. 1388 (U.S. 2011) (limits §2254(d)(1) review to record before state court)
- Harrington v. Richter, 131 S. Ct. 770 (U.S. 2011) (highly deferential review of Strickland under AEDPA)
- Yarborough v. Gentry, 540 U.S. 1 (U.S. 2003) (backward-looking, deferential Strickland standard)
- Lockyer v. Andrade, 538 U.S. 63 (U.S. 2003) (reasonableness standard under AEDPA review)
- Schriro v. Landrigan, 550 U.S. 465 (U.S. 2007) (procedural and substantive AEDPA deference principles)
- Premo v. Moore, 131 S. Ct. 733 (U.S. 2011) (AEDPA deference framework for state-court decisions)
- Felkner v. Jackson, 131 S. Ct. 1305 (U.S. 2011) (deference in §2254(d) analysis; evidentiary limitations)
- Renico v. Lett, 130 S. Ct. 1855 (U.S. 2010) (state-court findings and deference standards)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective assistance standard: deficient performance and prejudice)