Littlejohn v. Workman, No. 10-6148 (10th Cir. 2013)
Annotate this CasePetitioner-Appellant Emmanuel Littlejohn was convicted of two robbery-related charges and a charge of first-degree murder, arising from his role in a 1992 robbery of a convenience store in Oklahoma City. He received extended prison sentences on the robbery charges and a death sentence on the murder charge. Petitioner filed a Petition for a Writ of Habeas Corpus, claiming (relevantly) that his murder conviction and death sentence were obtained in violation of his constitutional rights. The district court denied all relief and Petitioner appealed on multiple grounds. Upon review, the Tenth Circuit affirmed the district court’s judgment on all grounds except for Petitioner's claims of ineffective assistance of counsel at the penalty phase and cumulative error. As to the ineffective-assistance claim, the Court reversed the judgment and remanded the case to the district court, with directions to conduct an evidentiary hearing and any further appropriate proceedings consistent with the Court's opinion. Additionally, because the resolution of Petitioner's cumulative-error claim could have been affected by the district court’s determination of his ineffective-assistance claim, the Court declined to address the merits of Petitioner's contentions concerning cumulative error. Instead, the Court directed the district court to vacate that portion of its judgment and to reconsider the cumulative-error claim.
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