Williams v. Ryan, 2010 U.S. App. LEXIS 22073

Williams was convicted and sentenced to death in Arizona for murder and related crimes; the conviction was upheld on direct appeal.
In his federal habeas petitions, Williams alleges Brady violations stemming from jailhouse letters (Sweat letters) suggesting an alternate suspect (Fields) and potential witnesses, which were not disclosed prior to trial.
The Sweat letters led to declarations from McKaney, Barnett, and Fields; the district court allowed limited discovery and ordered an evidentiary hearing on a Brady claim.
At sentencing, Williams sought funds for a mental health expert to assess drug dependence as a mitigating factor, which the state court denied.
Williams also presented crack cocaine addiction as mitigating evidence; the Arizona Supreme Court held no nexus between drug use and the murder was shown under state law.
The district court granted a COA on Brady and mental-health-evidence claims and certified the cocaine-mitigation issue for merits consideration.
The Ninth Circuit vacated the death sentence, remanded for an evidentiary hearing on Brady, and remanded with instructions to grant relief on the mitigation claim; otherwise, it affirmed other rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady claim viability and remedy	Williams argues Sweat letters were material and suppressed, requiring relief	State contends no proper exhaustion or materiality, and letters were not outcome-determinative	Remanded for an in-court evidentiary hearing on Brady claim
Mental-health evidence at sentencing under Ake	Williams sought indigent psychiatric assistance at sentencing as relevant to mitigating factors	State argued no threshold showing that mental state was at issue at the time of offense	Claim rejected on AEDPA deference; no independent showing of a significant mental-state issue at sentencing
Drug use as mitigating evidence	Drug addiction should be considered a mitigating factor without requiring a nexus to the crime	Arizona law requires a nexus between drug use and the offense to weight mitigation	Arizona's nexus requirement rejected; the death sentence vacated and remanded for resentencing to consider all mitigating evidence
AEDPA deference and retroactivity	N/A (points raised within Brady and mitigation claims)	N/A	Court adopts de novo review where state court failed to properly adjudicate claims; relies on established precedents
Remaining unbriefed issues	N/A	N/A	Not certified for relief beyond those addressed; other issues not granted

Brady v. Maryland, 373 U.S. 83 (1963) (supreme duty to disclose favorable evidence to the defense)
Kyles v. Whitley, 514 U.S. 419 (1995) (materiality; reasonable probability of altered outcome if disclosed)
Strickler v. Greene, 527 U.S. 263 (1999) (materiality; impeachment evidence as Brady material)
Jernigan v. United States, 492 F.3d 1050 (9th Cir. 2007) (en banc; second-suspect information generally material under Brady)
Earp v. Ornoski, 431 F.3d 1158 (9th Cir. 2005) (credibility and materiality issues require live testimony in some contexts)
Lockett v. Ohio, 438 U.S. 586 (1978) (mitigating evidence generally must be considered)
Eddings v. Oklahoma, 455 U.S. 104 (1982) (mitigating evidence may not be categorically excluded; weight determined by court)
Tennard v. Dretke, 542 U.S. 274 (2004) (no nexus requirement for mitigating evidence; considered in capital sentencing)
Smith v. Texas, 543 U.S. 37 (2004) (no nexus test for mitigating evidence; independent evaluation at sentencing)
Ake v. Oklahoma, 470 U.S. 68 (1985) (right to psychiatric assistance when mental state is at issue in capital case)