Jefferson v. GDCP Warden, No. 17-12160 (11th Cir. 2019)
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The Eleventh Circuit affirmed the district court's grant of habeas relief to petitioner, who was convicted of felony murder and sentenced to death.
The court held that the Georgia state habeas court's fact-finding was not entitled to deference in the pre-Antiterrorism and Effective Death Penalty Act of 1996 regime. In this case, the state habeas court adopted verbatim the state's proposed order; offered no guidance to the Assistant Attorney General drafting the proposed order; did not review the order, other than signing it, dating it, and changing the concluding sentence, notwithstanding the glaring errors it contained; and did so ex parte without so much as affording petitioner a chance to challenge any of it or propose an alternative order.
The court also held that the district court correctly determined that petitioner's trial lawyers' conduct fell beneath an objective standard of reasonableness when they failed to adequately investigate whether petitioner suffered from organic brain damage at the time of the killing. In light of the substantial evidence petitioner demonstrated showing that he suffered from organic brain damage, the court held that the district court did not err in finding that petitioner had been prejudiced by his lawyers' deficient performance.
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