Scoggins v. Hall, 765 F.3d 53

Scoggins was convicted of first-degree murder in 1998 and is serving a life sentence in Massachusetts.
He petitioned for habeas corpus under 28 U.S.C. § 2254 claiming ineffective assistance of counsel for not interviewing a key witness, Holbrook, or other potential witnesses.
The district court denied relief, concluding the state court’s Strickland decision was not an unreasonable application of federal law.
Massachusetts courts found waiver bar and no manifest unreasonableness in counsel’s decision not to interview Holbrook; Holbrook’s affidavit was deemed incredible.
On review, the First Circuit applied AEDPA deference and evaluated whether defense counsel’s actions were deficient and prejudiced the defense.
The court concluded that, even accepting a duty to interview Holbrook, the record did not show prejudice; other witnesses’ testimony would not have likely helped Scoggins.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to interview Holbrook was deficient performance	Scoggins argued counsel should have interviewed Holbrook before trial.	Holbrook’s statements at trial were credible; missing interview did not prejudice.	No substantial deficiency or prejudice shown; claim fails.
Whether failure to interview Campbell, Price, and Jermaine Campbell to rebut Holbrook was deficient	Counsel should have called these witnesses to rebut Holbrook’s testimony.	Potential testimony risk and lack of independent corroboration rendered it reasonable not to call them.	Defense strategy reasonably permissible; not deficient.
Whether waiver of the Holbrook interview claim forecloses federal review	Waiver should not bar review of ineffective-assistance grounds.	Massachusetts procedural waiver bars the claim.	Court reaches merits with AEDPA deferential lens; waiver does not compel relief.
Whether the state-court decision denying relief was an unreasonable application of Strickland under AEDPA	State court misapplied Strickland by failing to consider prejudice from not interviewing Holbrook.	State court’s application was reasonable given the record and credibility of Holbrook’s trial testimony.	State court’s decision was not unreasonable under AEDPA; relief denied.

Strickland v. Washington, 466 U.S. 668 (1984) (establishes deficient performance and prejudice standard for ineffective assistance)
United States v. Valerio, 676 F.3d 237 (1st Cir. 2012) (highly deferential review of counsel's performance under Strickland)
Harrington v. Richter, 131 S. Ct. 770 (2011) (AEDPA deference to state courts in habeas review)
Beard v. Kindler, 558 U.S. 53 (2009) (independent state-law ground can bar federal review)
Coleman v. Thompson, 501 U.S. 722 (1991) (state-court procedural defaults and federal review limitations)
Coombs v. Maine, 202 F.3d 14 (1st Cir. 2000) (preserves burden of rebutting factual presumptions under AEDPA)