Rimmer v. Secretary, Florida Department of Corrections, 876 F.3d 1039

In May 1998 Rimmer participated in an armed robbery at Audio Logic in Wilton Manors during which two employees were shot and killed; eyewitnesses later identified Rimmer and police recovered stolen property and the murder weapon linked to him.
Rimmer was tried in 1999, convicted on eleven counts (including two first‑degree murders), and sentenced to death; the Florida Supreme Court affirmed on direct appeal.
Postconviction, Rimmer claimed Brady violations based on two undisclosed police reports: an FDLE report (noting an FDLE photographic lineup and other investigative summaries) and a Plantation Police report describing a separate April 1998 murder.
At an evidentiary hearing, Rimmer’s trial counsel testified the reports were duplicative, not helpful, and could have been harmful if used; the state court found counsel credible and denied Brady relief; the Florida Supreme Court affirmed.
On federal habeas review the district court denied relief after reviewing Brady de novo and found the reports not material; this Court held AEDPA required deference to the state court’s factual credibility findings and affirmed denial of habeas relief as to the Brady claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether suppression of the FDLE and Plantation reports violated Brady	Rimmer: reports were favorable (exculpatory/impeaching) and their nondisclosure was material to the identifications and verdict	State: reports were duplicative, not favorable, and would not have undermined confidence in the verdict	Court: State court reasonably found reports not favorable or material; no Brady violation under AEDPA
Proper standard of review on federal habeas for state-court Brady ruling	Rimmer: district court may review materiality de novo	State: AEDPA mandates deferential review to state-court factual findings and credibility determinations	Court: AEDPA requires deference; district court erred by conducting de novo review and must defer absent unreasonable application of federal law

Brady v. Maryland, 373 U.S. 83 (prosecution must disclose evidence favorable to the accused)
Banks v. Dretke, 540 U.S. 668 (Brady materiality and prejudice standard)
Strickler v. Greene, 527 U.S. 263 (elements of a Brady claim)
Kyles v. Whitley, 514 U.S. 419 (consideration of withheld evidence in the context of the whole record)
United States v. Bagley, 473 U.S. 667 (definition of reasonable probability under Brady)
Harrington v. Richter, 562 U.S. 86 (AEDPA deference; state-court decisions must be objectively unreasonable to warrant relief)