Woodward v. Secretary, Department of Corrections, 3:13-cv-00155

Background

Petitioner Larry W. Woodward was convicted by a jury in Duval County, Florida of three counts of sexual battery (victim <12) and one count of lewd and lascivious touching (victim <16); state court sentenced him to life on the sexual-battery counts.
Woodward’s direct appeal and multiple Rule 3.850 post-conviction proceedings were litigated in Florida state courts; some post-conviction claims prompted remand for appointed counsel and additional hearings.
He filed a federal habeas petition under 28 U.S.C. § 2254 raising 15 claims, principally ineffective assistance of trial counsel (Strickland-related), involuntariness/ admissibility of his confession, Miranda/waiver issues, evidentiary rulings (Williams Rule / similar-fact evidence), and jury/ sentencing procedural challenges.
The district court applied AEDPA deference (28 U.S.C. § 2254(d)) and Strickland standards, found the state record adequately developed, and denied an evidentiary hearing.
Many claims were held procedurally defaulted/unexhausted because Woodward failed to present federal constitutional bases to state courts or abandoned issues on collateral appeal; where adjudicated on the merits, the court found state-court rulings reasonable.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness of confession / motion to suppress	Woodward: interrogation coercive (promised leniency, medical/medication/denied bathroom), so confession involuntary	State: record (transcript, hearing, expert testimony) shows no official overreaching; no express promise; totality of circumstances supports voluntariness	Denied — state courts’ rulings reasonable under AEDPA; admission harmless beyond a reasonable doubt (Brecht) given other strong evidence
Invocation/waiver of Miranda rights	Woodward: inaudible portions and misunderstanding show he did not validly waive right to counsel	State: Miranda warnings were given and acknowledged; no unambiguous request for counsel; defendant’s statements not credible as invoking counsel	Denied — waiver valid; no unequivocal request for counsel
Admission of similar-fact (Williams Rule) evidence	Woodward: collateral acts became feature of trial and unduly prejudicial; appellate error	State: admission under Florida Williams Rule; petitioner did not fairly present a federal due-process claim on direct appeal	Dismissed/Denied — procedurally defaulted/unexhausted; even on merits, no clearly established Supreme Court law violated
Failure to admit/offer defense evidence (H.B. running away; T.W. church forgiveness)	Woodward: exclusion/proffer errors deprived him of ability to present defense / impeach witness credibility	State: trial court allowed substantial cross-examination and defense theory; evidentiary rulings are state-law matters and not cognizable absent fundamental unfairness	Denied/Dismissed — no due process violation; claims unexhausted where applicable and meritless otherwise
Failure to provide presentence investigation	Woodward: sentencing without PSI violated state and federal rules and Constitution	State: claim was raised only under state law on appeal; no clearly established federal right to PSI for habeas relief	Dismissed — unexhausted and not cognizable on federal habeas
Ineffective assistance of counsel (various grounds: failing to investigate medical/insanity/intoxication, not moving for funds, not preserving issues on appeal, conflict of interest)	Woodward: Bell failed to investigate/consult medical experts, pursue insanity/voluntary-intoxication defenses, preserve suppression and other issues, and had personal bias/conflict	State: counsel consulted an expert on false confessions, made reasonable tactical choices; state post-conviction factfinding credited counsel; many claims abandoned on collateral appeal or otherwise unexhausted	Denied — state courts reasonably applied Strickland; petitioner failed to show deficient performance and prejudice; many claims procedurally barred

Key Cases Cited

Schriro v. Landrigan, 550 U.S. 465 (2007) (federal court need not hold evidentiary hearing when record refutes petitioner’s factual allegations)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA standard: deference to state-court decisions; relief requires unreasonable application of Supreme Court precedent)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
Brecht v. Abrahamson, 507 U.S. 619 (1993) (habeas harmless-error standard: substantial and injurious effect or influence)
Colorado v. Connelly, 479 U.S. 157 (1986) (confession involuntariness requires official coercion; voluntariness judged by totality of circumstances)
United States v. Bram / Brady / Fulminante framework cited by courts: Fulminante v. Arizona, 499 U.S. 279 (1991) (confession voluntariness assessed under totality; harmless-error considerations apply)
Johnson v. Zerbst, 304 U.S. 458 (1938) (valid waiver = intentional relinquishment of known right)
Davis v. United States, 512 U.S. 452 (1994) (suspect must unambiguously request counsel to invoke Sixth Amendment protections)
McNeil v. Wisconsin, 501 U.S. 171 (1991) (invocation of right to counsel must be clear and not judged by subjective likelihood)