Willie Trottie v. William Stephens, Director
2013 U.S. App. LEXIS 12046
5th Cir.2013Background
- Trottie was sentenced to death in Texas for the murders of Barbara and Titus Canada in 1993 and pursued federal habeas relief under 28 U.S.C. § 2254.
- Trottie alleged Strickland ineffective assistance of counsel, Brady suppression of evidence, and prosecutorial misconduct.
- The district court denied habeas relief; Trottie seeks a COA under § 2253(c).
- The district court and this court apply AEDPA deference, reviewing only the state-court decision on the merits and the record before that court.
- The court rejects Trottie’s claims for relief on the merits and denies a COA on all issues.
- The opinion discusses trial counsel’s investigation, presentence mitigation, and the handling of evidence and prosecutorial conduct.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance—failure to investigate/present witnesses | Trottie's counsel failed to investigate and call witnesses; mischaracterizes mitigation | State court found investigation/strategic decisions reasonable | No COA; state court’s Strickland application reasonable |
| Prejudice under Strickland and AEDPA | Missing testimony would have changed outcome | Record shows cumulative/insufficient impact | No COA; no reasonable probability of different outcome |
| Brady violations | Prosecutor suppressed a note by Trottie’s probation officer favoring defense | No suppression; note likely cumulative; no material impact | No COA; district court correctly denied Brady claim |
| Prosecutorial misconduct | Prosecutor referenced inadmissible tapes and biased the jury | Instruction and evidence favorable to state; no due process violation | No COA; misconduct did not substantially affect trial's outcome |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (Supreme Court, 1984) (establishes the two-prong standard for ineffective assistance of counsel)
- Williams v. Taylor, 529 U.S. 362 (Supreme Court, 2000) (defers to state-court application of Strickland under AEDPA)
- Slack v. McDaniel, 529 U.S. 473 (Supreme Court, 2000) (COA standard for habeas relief under AEDPA)
- Miller–El v. Cockrell, 537 U.S. 322 (Supreme Court, 2003) (establishes threshold for debatable constitutional claim in COA context)
- Renico v. Lett, 130 S. Ct. 1855 (Supreme Court, 2010) (AEDPA deferential standard and deference to state courts on factual determinations)
- Hernandez v. Johnson, 213 F.3d 243 (5th Cir., 2000) (noting death-penalty context and deferential review)