Winston v. Pearson, No. 11-4 (4th Cir. 2012)
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A Virginia jury convicted Petitioner-Appellee Leon Winston of capital murder. The court, following the jury’s recommendation, sentenced him to death. Petitioner's direct appeals failed and his conviction became final, at which point he sought habeas relief in state court. The Supreme Court of Virginia denied relief, rejecting Petitioner's requests for discovery and an evidentiary hearing. Petitioner then filed a habeas petition in federal court. The district court granted him an evidentiary hearing to explore whether his trial attorneys were ineffective for failing to raise the claim under "Atkins v. Virginia" (536 U.S. 304 (2002)) that his mental retardation categorically barred imposition of a death sentence. But the court reversed course and held that it was precluded from considering any evidence adduced during the federal proceeding. Looking only to facts presented in the state habeas proceeding and conducting a deferential review of the state-court decision, the court denied Petitioner's petition for habeas relief. Upon review, the Fourth Circuit vacated in part the district court’s decision on appeal, ordering it to conduct a de novo review of Petitioner's ineffectiveness claim while entertaining the evidence offered during the federal hearing. On remand, the district court granted Winston’s petition for habeas relief and vacated his death sentence. Virginia appealed, contending that intervening Supreme Court precedent eroded the foundation of the Fourth Circuit's prior opinion in the earlier case compelling the Court to forgo de novo review and instead accord substantial deference to the Supreme Court of Virginia's decision denying habeas relief. The Fourth Circuit disagreed and found nothing in recent Supreme Court decisions that called into question its reasoning in "Winston I," which, as law of the case. Reviewing Petitioner's ineffectiveness claim de novo, the Court agreed with the district court that Petitioner established that his trial attorneys rendered deficient performance that prejudiced him. The Court therefore affirmed the district court's grant of habeas relief.
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