Williams v. Beard
2011 U.S. App. LEXIS 4517
| 3rd Cir. | 2011Background
- Terrance Williams was convicted of first-degree murder and sentenced to death for the Norwood killing in 1986, after a prior spree and related offenses.
- The penalty phase included mitigation witnesses and a defense focus on Williams' youth, but the jury imposed the death penalty based on two aggravating factors.
- Williams challenged the verdict on collateral review, alleging Batson-based racial discrimination in jury selection and ineffective penalty-phase representation.
- The PCRA court held hearings; the Pennsylvania Supreme Court denied relief, applying a state rule (Uderra) that Williams must prove actual discrimination for Batson claims in collateral reviews.
- On federal habeas review, the district court denied relief but granted limited appellate-competent review on Batson and penalty-phase ineffectiveness; the Third Circuit rendered de novo review under AEDPA.
- The court addressed (1) Batson discrimination at voir dire, (2) accomplice-liability instructions, and (3) ineffective assistance of counsel during the penalty phase, ultimately denying relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson claim deference and merits | Williams demonstrates prima facie race-based strikes and discriminatory intent. | Commonwealth provided facially neutral reasons; Uderra not controlling here. | Batson claim rejected on merits after de novo review; no reversible discrimination found. |
| Production of prosecutor's notes & discovery | Williams sought contemporaneous voir dire notes for §2254 discovery and to probe state of mind. | Notes unnecessary; discovery fishing expeditions improper. | Discovery denied; no habeas error; district court properly limited discovery and declined evidentiary hearing. |
| Accomplice liability instructions | Instructions allowed conviction without proving certain mens rea for murder; due process violated. | Charge consistent with Pennsylvania law; not constitutionally infirm. | Accomplice instruction not unconstitutional; no due process violation. |
| Ineffective assistance of counsel at penalty phase | Panarella failed to investigate and present mitigating evidence of abuse and mental illness. | Pennsylvania Supreme Court reasonably weighed mitigation against aggravation; no prejudice proven. | No AEDPA relief; state court's Strickland ruling reasonable; prejudice not shown. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (three-step peremptory-challenge framework)
- Miller-El v. Dretke, 545 U.S. 231 (U.S. 2005) (further elaborates Batson framework and pretextual analysis)
- Holloway v. Horn, 355 F.3d 707 (3d Cir. 2004) (prima facie showing via statistics in Batson inquiry)
- Brinson v. Vaughn, 398 F.3d 225 (3d Cir. 2005) (pattern of strikes toward Black venire members)
- Bond v. Beard, 539 F.3d 256 (3d Cir. 2008) (comparator evidence and Batson step three relevance)
- Hardcastle v. Horn, 368 F.3d 246 (3d Cir. 2004) (pattern evidence and prima facie showing analysis)
- Abu-Jamal v. Horn, 520 F.3d 272 (3d Cir. 2008) (timeliness and contemporaneous objection requirements in Batson)
- Laird v. Horn, 414 F.3d 419 (3d Cir. 2005) (dueling accomplice-liability issues and due-process concerns)
- Woodford v. Visciotti, 537 U.S. 19 (U.S. 2002) (AEDPA prejudice and aggravating vs mitigating factors weight)
- Wong v. Belmontes, U.S. (U.S. 2009) (reconstructing record for prejudice in ineffective assistance)